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Consumer Focus Draft Annual Plan 2010-11 for consultation
9 November 2009 – 9 February 2010
Draft Annual Plan 2010-11 for consultation 2
Contents
Chairs’ foreword 3
Our annual plan 4
Work programmes for 2010-11 8
Consumer Focus 9
Consumer Focus Scotland 20
Consumer Focus Wales 31
Consumer Focus Post (Northern Ireland) 43
Supporting and empowering consumers 45
Partnership projects 48
Strengthening our capacity to deliver results 51
Pride in Performance 55
Funding and risks 57
How to respond and the way forward 58
Questions for stakeholders 59
Draft Annual Plan 2010-11 for consultation 3
Chairs’ foreword
When Consumer Focus was established in October 2008, we had an 18-month start-up
plan. This was designed to take us from the foundations built by our predecessor
organisations to a fully-functioning organisation with an unprecedentedly wide remit, able
to achieve a fair deal for consumers across the whole economy.
We also made a commitment to develop and champion creative solutions which really
help people, especially those who are more vulnerable.
We have made real progress towards those aims and now need to look ahead to
maximise our impact on consumers’ lives in the next period of our organisation's
development.
This document is the first annual plan in our corporate planning cycle for 2010-13. Our
corporate plan explains who we are, sets out the challenges we face (especially in light of
the recession), and our strategic aims over the next three years.
This annual plan sets out our key work areas for 2010-11 and our proposed forward work
programme for each part of Consumer Focus:
Consumer Focus
Consumer Focus Scotland
Consumer Focus Wales
Consumer Focus Post (Northern Ireland)
We invite you to let us know about any areas you think we’ve missed or could improve
upon. Our consultation period runs from 9 November to 9 February 2010 and includes
stakeholder events in Cardiff, Glasgow and London.
For more details see ‘How to respond and the way forward’ and a list of consultation
questions at the back of this document.
We would welcome your contribution so that we can ensure our annual plan is as robust
as possible in order that consumers increasingly receive a fair deal.
Larry Whitty
Chair, Consumer
Focus
Douglas Sinclair
Chair, Consumer
Focus Scotland
Vivienne Sugar
Chair, Consumer
Focus Wales
Rick Hill
Chair, Consumer
Focus Post
(Northern Ireland)
Draft Annual Plan 2010-11 for consultation 4
Our annual plan
In October 2008, the creation of Consumer Focus coincided with the emergence of the
most testing conditions for consumers in recent times. We approach the coming year
determined to design and deliver a programme of work that will stand up to these
conditions and address the key challenges facing consumers.
In preparing this draft Annual Plan we have set out to take full advantage of our ability to
work across different markets and services, across different regulatory regimes and
across different national and international jurisdictions.
We have a responsibility to safeguard and empower consumers, in line with our statutory
obligations. We have a specific responsibility to identify areas of detriment for vulnerable
and disadvantaged consumers. As well as undertaking work that benefits all consumers,
our proposed work for 2010-11 includes projects targeted at various disadvantaged and
vulnerable groups.
Consumer Focus is also concerned with the interests of consumers in the future.
Sustainability is one of our key duties; issues such as resource efficiency, waste
minimisation and mitigation of, and adaption to, climate change form part of our mission.
We strive to embed sustainability as an essential component in everything we do. This
involves both policies for changing the behaviour of companies and the priorities of
regulators and measures to encourage (and make easier) sustainable behaviour by
consumers themselves.
One of our four strategic aims (set out in our Corporate Plan) is to harness the appetite of
consumers to adopt more sustainable lifestyles. We therefore will also pursue specific
projects that tackle waste, climate change and public health, and projects to provide
clearer signals to consumers on sustainable choices. The extent to which we realise this
is a key test of how successful we are as an organisation.
Throughout this Annual Plan we have addressed the need for strong consumer research,
for high quality and detailed responses to regulatory and legislative developments and to
increasingly empower consumers to act.
Our proposed work for 2010-11
Consumer Focus champions the needs of consumers across England, Wales and
Scotland and, for postal services, Northern Ireland. We are able to combine powerful
advocacy at the European, UK and GB level, while delivering full and ambitious work
programmes in each nation.
The 2010-11 work programmes fully reflect Consumer Focus’s statutory responsibilities,
evidence and our criteria for work planning. It ensures that our investments are
proportionate to the impact we can achieve in delivering a fair deal for consumers.
Draft Annual Plan 2010-11 for consultation 5
Work area summaries
A. A fair deal for energy consumers
Energy prices remain high and scenarios from Ofgem and others indicate that they may
rise more steeply yet as environmental and renewable obligations are reflected in
consumer bills. Energy remains the lowest-rated sector in the Consumer Confidence
Index1. Our Extra Help Unit continues to receive thousands of distressing cases from
consumers forced to cope with the threat, or the harsh reality of, disconnection from an
essential service.
The thrust of our proposals is to highlight inefficient market structures, tackle poor
corporate behaviour and resolve quality of service issues that operate to the detriment of
energy consumers in general and vulnerable and disadvantaged consumers in particular.
We aim to improve the customer service in the sector, maintain the commitment of
Government and others to ending fuel poverty and maximise the opportunities for
consumers to use energy in a more sustainable way while ensuring a fair recovery of
costs associated with a low carbon energy industry.
The low carbon agenda is critical to our work for energy consumers. We will advance
arguments for consumers to benefit from smarter metering, clearer billing, tariffs that
encourage more efficient energy use, the promotion of domestic renewables and ‘whole
house’ solutions for those in fuel poverty.
B. A fair deal for postal consumers
The past year has seen both the Post Office network and Royal Mail going through an
extended and painful process of restructuring, with immediate impacts on consumers and
small businesses in England, Scotland, Wales and Northern Ireland.
Our statutory responsibilities cover both postal services and post offices. We will focus
our efforts on understanding the impact on consumers of significant changes to both
sectors. We will provide the evidence for a revitalised and innovative Post Office network
that meets consumer needs. We will also continue to work towards an effective and
efficient postal service that is affordable and meets the collection and delivery needs of
domestic and micro-enterprise postal consumers.
We will ensure that the process of transformation in both areas will be informed not only
by a powerful evidence base of consumer experience and expectation but also by an
agenda for innovation and change that meets consumer needs.
C. A fair deal in the financial services
The financial crisis and economic recession has removed access to affordable credit for
many consumers, certainly for those who need it most. It has put people’s homes in
jeopardy and plunged many consumers into serious debt. Financial services are another
sector that performs poorly according to the Consumer Confidence Index.
Our experience across different markets and services and our understanding of
consumer-centred policy making means that we will have an important contribution to
make to a successful reform agenda for the financial services markets.
1 The Consumer Conditions Survey is a major piece of research examining consumer experience
in the UK which asks consumers about their experience in 45 private sector markets. Consumer responses are aggregated and used to compile an overall Consumer Confidence Index, which provides the basis for comparing how consumers perceive the performance of a particular market against all others.
Draft Annual Plan 2010-11 for consultation 6
We will focus on a consumer agenda for regulatory reform and the impact of high cost
credit products on low income households.
To be successful we will need to work with stakeholders to understand and champion
ways in which the consumer interest can drive necessary changes to regulation and can
tackle the worst excesses of the high cost credit market.
D. Consumers and public services
In the context of severe pressure on the public purse and the current debates about the
reform of key public services, Consumer Focus will provide a clear perspective on how
consumers understand, navigate and benefit from public service provision.
With severe pressure on the public purse, there will continue to be important debates
about the reform of key public services. Consumer Focus will provide a clear perspective
on how consumers understand, navigate and benefit from well-designed public service
provision. We will seek to show how a focus on users' needs and experiences can be the
best way of maximising public value and facing up to hard choices.
Of course, this focus on public services will have a distinct national character in different
areas of Consumer Focus. We aim not only to drive improvements in each national
context but to learn and apply the lessons and examples of best practice that emerge
across public services in Britain.
E. Rights, regulation and redress
Consumer Focus will look across a range of markets to assess where consumer
detriment is greatest. In markets where competition has not delivered effective choice
and value or where consumer action has been unable to condition the behaviour of
market players, proportionate regulation and effective redress are critical to maintaining a
good level of consumer protection.
We propose to build on our ‘Rating the Regulators’ report to provide a positive and expert
perspective on how well-formed regulation - the right intervention but no more - can
enhance consumer welfare and provide broader economic benefits.
We propose a number of projects that address issues of digital inclusion and digital
rights. Our projects promote a fairer digital society. We will seek to maximise the benefits,
and minimise the risks, for consumers of the information society in which we live,
assessing and identifying issues of consumer detriment. We will work to reduce the
impact of the digital divide.
We will influence the large scale reforms of consumer law and civil justice systems at
home and in Europe to improve consumer protection and provide easier access to
dispute resolution and civil justice.
Draft Annual Plan 2010-11 for consultation 7
Responding to change
We will be strong advocates for consumers, using compelling evidence to make our case.
With limited resources and a wide remit, Consumer Focus must maintain a rigorous
process for prioritising work in order to deliver a fair deal for consumers in the most
effective and efficient manner.
The environment in which we operate is a challenging one. However, just because it is
challenging does not mean that those challenges will not change or grow. We recognise
the need to maintain flexibility in our approach so that we can effectively respond to
changes in the consumer environment across the nations that may occur throughout the
financial year.
If new or unexpected events occur, we will re-evaluate and balance our workload,
adopting new projects where necessary and discontinuing or postponing work that is no
longer relevant or deemed a lesser priority.
As well as today’s consumers, we are concerned with the interests, rights and
responsibilities of the consumers of tomorrow. In the face of the growing challenges of
climate change, resource scarcity and the threat to social cohesion, Consumer Focus is
working to ensure that consumer choice and behaviour increasingly reflect sustainable
patterns of consumption.
Sustainability in all respects – environmental, economic and social – is a particularly
important feature in our work on energy and significant in other areas such as food.
The sustainability dimension needs to feed into all our work; the aim being that both
business offers and consumer preferences make it easier for consumers to make more
sustainable choices.
As an organisation we are committed to operating in a manner that promotes sustainable
practices and will review regularly how we operate.
Draft Annual Plan 2010-11 for consultation 8
Work programmes for 2010-11
Consumer Focus; Consumer Focus Scotland; Consumer Focus Wales and Consumer Focus Post (Northern Ireland)
Work programmes for 2010-11
We set out the projects we think will have the most impact for consumers in 2010-11.
They are separated into four distinct programmes:
Consumer Focus
Consumer Focus Scotland
Consumer Focus Wales
Consumer Focus Post (Northern Ireland)
This is the main area on which we would like your comments. Please tell us where you
think we can improve this draft plan, whether by adding new projects or removing or
changing proposed ones.
Draft Annual Plan 2010-11 for consultation 9
Consumer Focus
A. A fair deal for energy consumers
1. Vulnerable energy consumers
The number of households struggling to pay their energy bills has grown considerably
over the past five years. Current projections on energy prices raise the prospect of this
situation worsening. Consumer Focus will continue to champion the interests of
consumers who are in, or at risk of falling into, fuel poverty.
To mitigate some of the most serious consequences we have worked closely with Ofgem
on a fast track review of disconnection of vulnerable consumers and have begun a joint
review of supplier debt and disconnection policy and process.
For the coming year we propose to monitor closely the implementation of those debt and
disconnection recommendations, and of the levels and types of debt-related calls to
Consumer Direct and our dedicated Extra Help Unit.
We also propose producing consumer surveys, personal video testimony and research
on the consumer experience of relevant advisory services to give voice to the experience
of households in fuel poverty and maintain the commitment of Government and others to
a coherent strategy to tackle fuel poverty.
We aim to:
provide an authentic consumer voice to inform the continuing development of a coherent fuel poverty strategy
play a leading role among stakeholders in making the case for policies that deliver fairness in pricing, income and energy efficiency for fuel poor households
produce clear evidence of any material improvement in suppliers’ debt and disconnection practices
achieve improvements to the self-regulatory framework for vulnerable disconnections (ERA Safetynet)
Achieving these goals will help us to:
work towards an end to the disconnection of vulnerable consumers
ensure energy consumer debt is addressed at an earlier stage
provide better information for consumers at a disadvantage and advice providers
reduce the numbers of households suffering in fuel poverty
Draft Annual Plan 2010-11 for consultation 10
2. The structure of energy markets
There are stubborn questions about whether wholesale and retail energy markets are
sufficiently transparent and whether they function in the interests of consumers.
Consumer Focus will continue to monitor a number of key indicators of healthy
competition including the relationship between wholesale and retail energy prices and
levels of market transparency. We will also identify and pursue potential consumer
benefits within the various market governance and code mechanisms.
Given the relevance of various European legislative and regulatory initiatives, we will
work with the European Commission and other stakeholders to ensure a UK consumer
voice is heard during the implementation of new European policies, particularly in relation
to the third EU energy liberalisation package and the third EU Energy Security and
Solidarity Action Plan.
Within this work area we propose a specific project on consumer welfare within the Liquid
Petroleum Gas and Heating Oil markets. These are markets of limited choice and rising
consumer prices. We intend to build on scoping work in these unregulated markets to
translate market and stakeholder research into an advocacy project that would champion
the interests of consumers dependent on these fuels to heat their homes.
We aim to:
respond with authority to a range of competition and regulatory investigations and reviews into the operation of energy markets
provide a strong and clear consumer voice at all levels of industry rules and policy development
achieve changes to EU legislation and policy that reflect UK consumers’ needs and concerns
articulate a strong case for any appropriate regulatory and/or voluntary changes to reduce the cost of heating fuels for consumers and improve the energy efficiency of their homes
By contributing to key regulatory and market reviews we can promote:
greater market transparency and a reduction in barriers to entry
a healthily traded wholesale energy market
a reduction in the costs passed on to consumers
strong and proportionate regulation to prevent abuses of market power
the creation of a more competitive market for domestic heating fuels
3. Energy company performance
A critical role for Consumer Focus is to monitor and report on the quality of customer
service, the effectiveness of complaint handling and redress arrangements and the
provision of transparent pricing information. We will continue to interrogate other areas of
consumer detriment such as complex tariff structures, mis-selling and billing errors. We
will participate in public consultations to effectively implement the consumer protection
provisions in the third EU energy liberalisation package into national law. We propose to
work with industry and the regulator to identify best practice and encourage the industry
to improve existing policies and practices to drive up standards.
Draft Annual Plan 2010-11 for consultation 11
We aim to improve the functioning of energy retail markets for all consumers by enabling
them to use timely and accurate information to access the best deals and payment
methods, to use performance league tables and other means of comparing customer
service levels. We will build on this activity to develop an effective new consumer
empowerment model for energy consumers, drawing on work by predecessor bodies and
exploring existing practice in the wider advice provision community.
Within this work area we propose a specific project to investigate how well micro-
enterprises are served as energy consumers in relation to price, contact terms, customer
service and redress arrangements.
We aim to:
raise awareness of the Ofgem retail market remedies, the Consumer Focus ‘Confidence Code’ and ‘Knowledge Base’
target online empowerment resources for consumers and for other agencies
ensure consumers have access to up-to-date, meaningful and impartial performance information on their energy suppliers to allow them to make informed choice
This will help us to ensure that:
companies feel a real incentive to improve their complaint handling processes
redress arrangements are understood by consumers and advice agencies and work effectively
standards of customer service improve across the energy sector
consumers make better switching decisions and access the most appropriate energy deal available
4. Carbon transition and consumers
To achieve carbon reduction targets will require much greater investment in demand-side
solutions. This is likely to involve the installation of expensive energy efficiency products,
district heating and micro-renewables in existing homes and communities. Policy
solutions to the global challenge of climate change are being developed in European and
international forums, as well as through national programmes. We will engage with
relevant third sector stakeholders to develop and promote effective solutions for
consumers, including complementary measures that support adaptation to climate
change.
The scale of the changes proposed for energy use in British homes means that,
alongside the long-term benefits, there is significant scope for consumer detriment in
terms of cost, time, privacy, and safety. Working with our National Social Marketing
Centre, we propose gathering evidence on consumer attitudes to, and public acceptability
for the changes, in order to identify the obstacles to, and opportunities for, public
engagement in the low carbon transition, high cost energy efficiency measures and
household and community level renewable energy.
Consumer Focus will also work to limit disproportionate payments for people on low
incomes or in hard-to-heat homes. The work will involve assessing the size and incidence
of increases in energy costs and identifying the impact for different types of household.
The work will propose and test alternatives to the 'energy customer pays' model, taking
into account fairness, affordability and administrative simplicity. It will also look at different
sources eg 'beneficiary pays', 'tax-payer pays' and 'shareholder pays'.
Draft Annual Plan 2010-11 for consultation 12
We aim to:
challenge and test the orthodox arguments for cost-reflective charges on customers towards equity based charging for utilities
influence policy development in order to limit disproportionate disturbance and expense, especially in terms of payments for people on low incomes or in hard-to-heat homes
ensure relevant programmes are informed by real consumer attitudes and experience
ensure consumers’ needs are incorporated into planning for inevitable climate change
Over the longer term this work will enable:
a sound basis for an energy services market that delivers affordable energy services to all consumers
Government and agencies to better promote the uptake of carbon efficient and climate resilient homes
B. A fair deal for postal consumers
5. Universal Postal Service fit for consumers
The Universal Postal Service (UPS), and specifically the uniform pricing element,
provides a clear benefit for consumers, especially for rural and remote consumers.
Protecting the UPS has a distinct benefit for all consumers, particularly those who are
vulnerable or at a disadvantage.
We will represent postal consumers’ views so they are properly considered and
incorporated in policies or regulatory changes resulting from market reviews undertaken
by the postal regulator. This will include input into reviews of Price Controls. This work will
review existing procedures with regard to delivery and collection exceptions, and will
monitor the Universal Service Provider to ensure that quality of service, mail integrity and
complaint details are being kept to the required level.
We aim to deliver:
a strong evidence-based submission to the 2010 Price Control that encapsulates the views and experiences of postal consumers
a detailed review of existing procedures with regard to delivery and collection exceptions and ensuring that the system is fair for consumers
The longer term benefit will be:
a strengthened universal postal service which reflects market trends and, most importantly, the needs of postal consumers
Draft Annual Plan 2010-11 for consultation 13
6. Fair postal services outside the universal service obligation
This project will undertake research into those postal services which do not fall within the
definition of the UPS.
Specifically we will consider areas such as the levying of surcharges on orders by some
online and mail-order retailers and their couriers. It will examine the delivery convenience
schemes run by non-licensed operators and other companies which provide deliveries,
and highlight delivery convenience schemes which could be used by licensed operators.
We aim to deliver:
detailed interrogation of company justification for practice of surcharging
significant improvements in operator/consumer communication to ensure that charges are highlighted for consumers
improved customer understanding and awareness of mail opt-out schemes
This will lead to:
improved convenience and consistency of delivery for customers
an end to unjustified delivery surcharges
the ability for consumers to more easily opt out of receiving direct mail
7. A strong Post Office network
Consumer Focus has a statutory responsibility to monitor the number and location of post
offices. We also have a responsibility to operate a code of practice with Post Office Ltd
(POL) on closures, relocations and conversion to outreach facilities.
As part of the Post Office network change programme (NCP) an initial 500 outreach
services were established to maintain services, predominantly in smaller and remote rural
locations that could no longer support full-time branches.
We propose to use tracker surveys and impact studies to evaluate the impact of changes
to the Post Office network, including the long-term impact of the NCP on quality of service
at branches, changes in service provision and access to community services.
We also propose an advocacy programme to influence Government and POL decision-
making on the future of the network. We will promote new products and services which
consumers want and which could be offered through the Post Office network, and
promote the financial viability of the network while supporting specific consumer
objectives.
We also propose a specific project in this area. We will build on our work in 2009-10 to
increase understanding of the consumer detriment caused by problems in accessing the
post office and essential community services. We intend to use a specific example of a
community in transition, such as a market town. Recommendations will be made to
promote improved access to essential community services, taking account of common
and specific barriers to access and service provision.
We aim to ensure that:
there is a greater awareness of the code of practice and improvements in the capacity of local authorities to meet the needs of local consumers
decisions on changes to the network are properly informed by consumer engagement
Draft Annual Plan 2010-11 for consultation 14
we have a sound evidence base for an awareness campaign on the impact of closures on quality of service and community provision
improvements to outreach services and the potential rollout of the ‘essentials’ model, meet consumers’ needs
there is an increased awareness among relevant stakeholders of best practice examples of innovative provision of services, including co-location
These outcomes will help us to achieve:
a stronger code of practice providing an effective set of consumer protections
greater community resilience in the event of future changes in service provision
an improvement agenda for quality of service, queuing and other areas of detriment for Post Office consumers
increased and more innovative service offerings, including more Government and financial services offered through post offices
better understanding of the capability of social enterprise organisations to offer post office services through innovative means
8. Empowering postal consumers
Consumers need accurate and useful information, giving them the knowledge, tools and
skills to effectively advocate on their own behalf. Consumer Focus has a depth of
experience in the postal services and other sectors.
Harnessing the power of consumer action will place clear incentives on postal service
providers to drive up overall standards of service in the industry.
We propose to develop an effective new consumer empowerment model for postal
consumers, drawing on work by predecessor bodies and harnessing existing structures in
the wider advice provision community.
We will use our expertise to develop targeted online empowerment resources for
consumers and for other agencies (via the Partners’ site and Knowledge Base).
The impact will be:
unbiased consumer information that is accessible, factually correct and up to date
continued development of relationships and partnerships with advice agencies
Over the longer term this will drive:
improved overall service standards, and performance in the postal industry, as consumers are made more aware of their rights and put pressure on industry to deliver them
C. A fair deal in financial services
9. Regulation of financial services markets
The financial crisis of 2008 had many causes, but flaws in the design and operation of the
regulatory framework played their part. Our ‘Focus on Finance’ series asked important
questions about the banking crisis and the future shape and regulation of financial
services markets.
Draft Annual Plan 2010-11 for consultation 15
We propose to develop a strand of work that will enable us to contribute to the design and
delivery of future reforms so that the interests of consumers remain centre-stage. We will
contribute a consumer perspective on how a regulatory framework which is more
responsive to the consumer interest would generate greater competition, enhanced
financial capability, increased engagement by consumers with financial services and
reduced mis-selling of financial products.
Proactive, affirmative consumer protection is essential for the safety and stability of the
financial system. Consumer Focus will engage and collaborate in initiatives being
undertaken by the EU and international institutions aimed at restoring confidence and
improving financial markets which are likely to affect consumers in the UK.
Within this work area we propose a specific project to consider the impact of
consolidation in the personal banking sector. A perceived lack of competition raises
concerns about the ability of consumers to exercise real choice and thereby influence
market behaviour.
This project will develop interventions on both market structure and consumer behaviour.
In particular it would draw upon our cross-cutting work on behavioural economics to gain
insights on how to improve market function for consumers.
We aim to achieve:
a clear statement of the regulatory reforms that are necessary to protect consumers
a mechanism for consumer-centred public debate on the future regulation of financial services
strengthened consumer protection policies at the centre of European and international reforms for financial services regulation
The longer term benefits will be:
financial services regulation that is able to help rebuild consumer confidence
greater levels of informed switching among all groups of consumers
market reforms that bring greater levels of consumer power to bear on the personal banking sector
10. Consumers at a disadvantage in financial services markets
The consequence of the financial crisis and economic recession on consumers has been
profound. Access to affordable credit has dried up, levels of indebtedness are rising and
the pressure on many homeowners has become unbearable.
We propose to monitor the effectiveness of measures taken on secured and unsecured
lending. Our work will examine the practices of lenders, landlords, debt collection
agencies and debt management companies to ensure they are fair, reasonable and
proportionate, and do not cause undue harm and distress to vulnerable consumers.
Within this work area we will also focus on some of the manifestations of high cost credit.
Approximately 2.3 million people use home credit. Many of these are from the most
disadvantaged groups. Provision of lower-cost options is piecemeal and there is
insufficient capacity to meet the needs of the poorest group.
We will identify and evaluate viable alternatives of affordable lending in order for
Consumer Focus to formulate a coherent and authoritative response to the growth and
impact of high cost credit such as home credit and payday lending.
Draft Annual Plan 2010-11 for consultation 16
We aim to promote:
safeguards to prevent the recurrence of over-indebtedness
strengthened measures to prevent unscrupulous lending
raised public awareness of debt problems faced by disadvantaged groups
Over the longer term these will enable us to achieve:
increased protection for those at risk of losing their homes or unable to make ends meet under the burden of debt
improved access to affordable credit
more effective regulation of high cost credit
D. Consumers and public services
11. Understanding the consumer experience of public services
Our work on public services will have a distinct national character in each part of
Consumer Focus. The impact of it will be not only to drive improvements in each national
context but for Consumer Focus to learn and apply the lessons and examples of best
practice that emerge across public services in Britain.
We propose developing more effective ways of collecting data regarding consumer
experiences of public services, a focus on navigating public services and how digital
delivery might increase levels of consumer engagement.
There is an information gap about consumer detriment in public services. Using desk
research and stakeholder input we will identify and assess the current mechanisms for
recording data, and explore what value they have in revealing consumer experiences.
The findings will inform a project to develop more comprehensive, coherent and uniform
ways of collecting data on consumer experiences of public services.
Navigating public services and Government support can prove difficult for many
consumers, often more so for groups which have the greatest reliance on them. We
intend to undertake detailed research into the experiences of a specific user group in
accessing the key services they require. We will use the research to establish a model for
helping consumers get the information and services they need.
The latest Digital Britain plan promises to put all public services online. There is also a
growing focus on electronic management of people’s personal data, especially in
healthcare. Using research and workshops with consumers and stakeholders, we will
evaluate how the inherent potential of digital technologies can give consumers – including
those in marginalised communities - more voice and influence.
We aim to:
achieve a stronger understanding of consumer detriment in public services
gather compelling evidence of user experience in accessing and navigating public services
deliver a mechanism to provide open data on consumer experiences of public services
use the opportunity for stakeholders to assess the consumer benefits of increased engagement through digital delivery
Draft Annual Plan 2010-11 for consultation 17
This will help us to promote:
improvements to national and local digital public service policy and practice which make services easier to use
consumers who are empowered through new ways of online participation with public services
local authority and community led responses to essential service provision
improved data collection and management policies
E. Rights, regulation and redress
12. Digital rights and digital inclusion
The Government aims to enable all consumers to benefit from using digital technology as
part of their daily lives and to have access to online provision of services, including public
services. Consumer Focus aims to ensure that a universal service commitment in
broadband will avoid creating a 'digital divide' through unfair differential access.
We propose an area of work that argues for a universal service obligation that recognises
affordability, accessibility and ease of use as being key issues for consumers. This work
will identify adverse impacts or exclusion issues and highlight them to Government.
We propose continuing our work to create an awareness of a coherent concept of
consumer digital rights, in the United Kingdom and across relevant European and
international jurisdictions. We will seek support for this approach from Government,
industry and consumer organisations. We will also examine each of the consumer rights
areas and appropriate regulatory frameworks and redress mechanisms, but will focus on
issues related to privacy and data security aspects of new technology. We will also
continue our work to achieve a fair balance between consumers and intellectual property
rights' holders.
We aim to achieve:
clear guidance to Government regarding possible unintended consequences of its digital strategy
stronger partnerships and cross-sector working
a coherent proposal to Government and industry for a digital rights charter
improvements to the European regulatory framework, and where relevant international agreements
These will help us to promote:
a fairer process in rolling out digital technology
increased protection for consumers and a decrease in any digital divide
a data protection regime that meets consumer needs
better public awareness and consumer empowerment in relation to their own digital rights
a fair balance between consumers and holders of intellectual property rights
Draft Annual Plan 2010-11 for consultation 18
13. Mobile and fixed line phones
We propose to continue and develop our current programme of advocacy around
identified areas of consumer detriment in the telecommunications sectors. This work will
be designed to complement and support the work programme of the Communications
Consumer Panel.
Additionally, we will address new and emerging issues of consumer detriment in the
mobile phone sector, identified through established stakeholder relationships and
intelligence and through our own expertise of customer service and switching issues in
other markets. In particular we will focus on complex tariffs, consumer information, ease
of switching provider, levels of customer service and complaint handling.
We aim to achieve:
a sound comparative basis to assess improvements in telecommunications providers on quality of customer service, tariff complexity and switching
greater level of consumer and advice agency awareness of hidden charges and tariff characteristics
By working with key stakeholders, we will promote:
measurable improvement in company performance in areas of greatest consumer detriment
consumers who are better informed, more active and able to identify the right deal for them
14. Consumer law
The European Commission published a draft Consumer Rights Directive (CRD) in 2008
to simplify, update and harmonise existing EU consumer protection legislation. In July
2009, the UK Government published a Consumer White Paper which aims to modernise
UK consumer law.
This work area will consider the gaps and weaknesses in our current domestic consumer
protection framework, building on work in relation to the CRD. We will also examine and
consider rights which are not adequately protected and will build on our previous work on
consumer collective redress to explore the best approach for embedding collective
redress in the Consumer Rights Bill.
We also propose to respond to the Civil Justice Council review of Lord Woolf’s Civil
Procedure Reforms. We will promote the interest of court users to the Civil Justice
Council and ensure that consumers’ interests are at the heart of the proposed reforms.
In particular we intend to explore regulatory gaps in our civil justice system and examine
the growing mediation market. We will also look at the lack of regulation of the third party
insurer market and the take-up and the use of legal expenses insurance.
We aim to:
radically improve the draft CRD to improve consumer rights
win the argument for the closure of the loophole which outlaws unfair commercial practices but does not give consumers a direct right of redress under the regulations
achieve clarity about whether Legal Expense Insurance is useful as a viable means of widening access for those who otherwise would not be able to afford mediation services
Draft Annual Plan 2010-11 for consultation 19
This will enable us to:
strengthen consumer protection law in the UK
provide consistent rights and redress protection across the goods and services consumers purchase
strengthen mediation industry standards to provide quality assurance and a complaint mechanism for consumers who are being encouraged to use it
achieve guidelines or regulations put in place to prevent third party insurers from undervaluing claims, particularly when there is an imbalance of power and no independent oversight
15. Regulation and redress
Consumer Focus's experience across a range of markets and services has shown that
well-formed regulation can maximise consumer interests and provide wider economic
benefits. In cases of market failure or detriment caused by market wide behaviours it is a
necessary way of protecting consumers from unfair treatment or poor standards of
company performance.
We propose to continue our work putting consumer interests at the heart of regulatory
practice, by building on our 'Rating the Regulators' work to identify good and bad practice
in regulatory design and delivery.
We will provide effective consumer input to public policy debate on the future direction for
regulation and specific regulatory reform initiatives.
At a basic level, consumers want their complaints dealt with efficiently, transparently and
fairly by those whom they complain about. We propose a specific project to benchmark
complaint handling across different markets and to identify why consumers give up on
complaints before they get a satisfactory resolution.
We aim to:
input to BIS’s new regulatory policy committee
engage with regulators with regard to their level of performance against key consumer criteria
ensure that Consumer Focus and others have a sound cross-market evidence base on complaint handling standards
ensure that Consumer Focus is better able to respond to how consumers actually engage with company redress procedures
This level of engagement will enable us to promote:
improved complaints service and redress schemes in poor performing sectors
improved approaches to better regulation
Draft Annual Plan 2010-11 for consultation 20
Consumer Focus Scotland
A. A fair deal for energy consumers
S1. Evaluating the effectiveness of the Energy Assistance Package for rural, remote and island consumers
The Energy Assistance Package (EAP) was launched by the Scottish Government in
April 2009, with the aim of reducing fuel poverty in Scotland. Successful delivery of the
EAP is critical to reducing fuel poverty in Scotland in general, and because households in
rural, remote and island Scotland face particular issues in this respect.
The number of households experiencing fuel poverty is influenced by the cost of energy,
household income and the energy efficiency of the building, as well as the circumstances
of the household itself. Long-term rises in the cost of energy, together with the current
recession, are expected to increase the numbers of households in fuel poverty. Rates of
fuel poverty are higher in rural areas than in urban parts of the country, because
households without access to mains gas generally have higher heating costs. In addition,
rural houses tend to be less easy to treat in terms of energy efficiency, and, especially in
northern Scotland, are located in areas where weather conditions increase the need for
heating.
The EAP provides a service for consumers in four stages:
1. energy efficiency advice is available to everyone
2. depending on household circumstances, a benefits check is provided. If appropriate, consumers are also made aware of the availability of social tariffs offered by their current energy supplier
3. consumers who are likely to be eligible for physical energy efficiency assistance measures from energy suppliers under the CERT (Carbon Emissions Reduction Target) scheme are referred to suppliers who provide that service
4. additional public sector funded measures are provided, such as new heating systems, and potentially include microgeneration for households where mains gas is not available
Consumer Focus Scotland intends to carry out this research to improve understanding of
issues around the delivery of solutions to fuel poverty in rural areas in Scotland, with the
aim, in line with our membership of the Fuel Poverty Forum, of improving the delivery of
the EAP in those areas.
The research report will have two elements:
1. focus groups on the delivery of services from the perspective of consumers who have benefited from assistance
2. looking at the effectiveness of promotion and delivery from the perspective of local agencies
Draft Annual Plan 2010-11 for consultation 21
We aim to:
Improve the quality of service provided by the Energy Assistance Package to vulnerable consumers in rural, remote and island areas, in line with the findings of the research. We anticipate that the study will highlight both successes and areas for improvement in addressing fuel poverty in rural, remote and island communities. Consumer Focus Scotland will then campaign for any identified improvements to be delivered as part of the package
S2. Empowering consumers in Scotland to make informed decisions on their options to get a better deal on their energy supply
Consumer Focus data shows clearly that energy prices have effectively doubled between
2003 and 2009. This trend is expected to continue. There are clear strategic challenges
in the structure and operation of the energy market that have a fundamental impact on
consumers across Great Britain. In the devolved context, measures by the Scottish
Government and energy suppliers to address energy efficiency will reduce individual
consumer’s fuel bills.
Research undertaken by Consumer Focus Scotland demonstrates that many consumers
would like additional targeted assistance and assurance to reduce their bills by switching
supplier or gaining access to a social tariff. Therefore, a key element of the work is a
programme which will build capacity among frontline advice service providers so they are
better able to support and empower Scottish energy consumers to overcome the
perceived and real barriers to making informed choices. There will also be a targeted
campaign highlighting the opportunity for consumers to make these decisions with expert
help.
This work will learn from, and build on, the successful Energy Best Deal campaign
undertaken in England and Wales by Ofgem and Citizens Advice Bureaux.
We aim to ensure:
a more effective switching advice and support service is added to the range of
financial and energy advice provided at local level for disadvantaged consumers
reductions in fuel bills for individual consumers
The benefit to consumers will be:
increased confidence to take advantage of their power as consumers to seek
better terms of supply of energy
reduced energy bills for those who choose to change tariff
improved capacity among support agencies will widen the range of consumers
who are able to access these benefits
consumer demand changes in suppliers’ behaviour will benefit all consumers in
the longer term by motivating energy suppliers to become more responsive to
consumers’ needs
Draft Annual Plan 2010-11 for consultation 22
B. A fair deal for postal consumers
S3. Research into Post Office Business as Usual (BAU) closures in Scotland
There is concern about the impact of BAU closures on consumers in the short-term while
their local post office is closed – particularly in remote rural areas in Scotland where the
Post Office fulfils a vital social function, where small businesses are reliant on the Post
Office and its services, and where the local Post Office is often based in ‘the last shop in
the village’. There are also concerns about the impact that such closures might have on
longer-term viability of the Post Office network in Scotland.
There are two main elements to the proposed work:
1. data analysis to determine the pattern of BAU closures
2. qualitative research in selected areas to ‘dig deeper’ behind the statistics and examine the impact of BUC on consumers – with a particular focus on those vulnerable consumers most reliant on Post Office services
BAU closures will always happen; however, through this research we will seek to
enhance the consumer interest in this area, and bring about improvements in how Royal
Mail prepares for and manages these closures to reduce the impact on consumers.
The benefit to consumers:
over time BAU closures will become less prevalent and new measures will be put in place to minimise the impact of these closures on consumers
S4. Mapping of Government services in Scottish Post Offices
The Post Office network in Scotland, as in the rest of the UK, recognises that it needs to
reform and modernise, if it is to be sustainable and offer an attractive range of high
quality services and products to consumers. There is general consensus among policy
makers that one way in which this development can take place is through the Post Office
widening the range of services it offers to customers. One of the core services that should
be delivered to consumers is an increased number of Scottish Government and local
authority services. This would increase awareness among these consumers of a range of
other Post Office products and services. This would support the sustainability of the Post
Office network by encouraging new or returning customers, and would help to improve
access to public services for consumers.
We aim to commission a mapping exercise that will:
provide comprehensive, robust information about the services that the Scottish Government and each of the 32 local authorities in Scotland offers through Post Offices
identify the different outlets and provision points that local authorities currently use to deliver relevant services within their area
produce case studies of good practice where the Scottish Government or Scottish local authorities are using Post Offices for the delivery of services
explore the challenges/barriers that the Scottish Government and local authorities face in using Post Offices to support service delivery
highlight relevant examples of good practice from abroad that might be used to inform improvements in this area in Scotland
Draft Annual Plan 2010-11 for consultation 23
The benefit to consumers will be:
consumers will benefit as they will be able to access an increased range of services through their local Post Office, and will have a more sustainable Post Office network to access services through in the future
C. A fair deal in financial services
Consumer Focus Scotland has no separate plans in this area.
D. Consumers and public services
S5. Food services for older people in the community
Older people living in the community are one of the specific vulnerable groups highlighted
in the national food policy ‘Recipe for Success’ and in the ‘Healthy Eating Active Living
Action Plan’.
Consumer Focus will undertake research on food services for older people living in the
community via questionnaires sent to all local authorities and selected consumers. The
main objectives are to assess current policies and services that focus more on the
community rather than on institutions for the long-term care for older people, and to
establish any gaps in this provision.
There has been little work in this area in Scotland. The findings of this work will be used
to inform government policy in this area and the approaches adopted by local authorities
and the voluntary sector.
The benefit to consumers will be:
depending on the findings of the research, it could ensure improved food services for older people in Scotland
S6. Service user involvement at national level in relation to social care policy
The involvement of consumers of services, or of people able to advocate for particular groups of consumers, is one of the main ways in which service planners and service providers can ensure that services meet people’s needs. While this kind of involvement has developed in different settings and to different extents, Consumer Focus Scotland has a concern that in some policy areas this is done less effectively at national level.
This work will map the extent to which the voice of service users is heard in the
development of policy at national level in relation to social care services. It may be useful
to look at models for how this is done in other countries.
If it appears necessary to lobby for more effective representation of service users at
national level, this policy paper will provide the basis for such lobbying.
The benefit to consumers will be:
more effective representation of the consumer interest at national level, and a greater awareness of this representation and its impact
Draft Annual Plan 2010-11 for consultation 24
S7. User Focus: How well are scrutiny bodies performing?
In April 2009 Scottish Ministers directed the bodies that inspect, regulate and audit
Scottish public services to improve their ‘user focus’. This was followed by a duty to
promote continuous improvement in user focus, contained within the Public Services
Reform Bill, published in mid-2009.
This project will establish to what extent scrutiny bodies are meeting these tests.
The project proposes to cover eight scrutiny bodies:
NHS QIS
Social Work Inspection Agency
Care Commission
Scottish Housing Regulator
Audit Scotland
HM Inspectorate of Education
HM Inspectorate of Constabulary for Scotland
HM Fire Inspectorate for Scotland
The project will take place during a period of change for three of the scrutiny bodies
identified. The Public Services Reform Bill, currently before Parliament, will create
Healthcare Improvement Scotland (a new body taking on powers from NHS QIS) and the
Social Work and Social Care Inspectorate (a merger of the current Social Work
Inspection Agency and the Care Commission). The project will therefore not start until
late 2010 to allow for this bill to have been passed but before the new organisations are
formed (expected in 2011/12). Publishing the findings during the development of these
new organisations will help ensure that user focus is embedded in their processes.
This work will examine how far public services scrutiny bodies have come in developing
user focus, and rate their performance according to the seven tests of user focus,
identified by the User Focus Action Group in 2008 and developed by Consumer Focus
Scotland in 2009. Scrutiny bodies will be sent requests for information on their user focus
strategies and interviews will be carried out with senior managers in each of the bodies.
This project will support the development of a culture of ‘user focus’ in scrutiny bodies by
improving awareness of good practice.
The benefit to consumers will be:
in the longer term, user focus in scrutiny will contribute to the development of consumer-focused public services
S8. The consumer perspective on public sector performance reporting
In recent years there has been an international trend towards using outcomes to measure
the performance of public services (OECD, 2005, Modernising Government: The way
forward). This follows widespread criticisms of input and process measurements for their
lack of relevance to consumers and citizens.
Part of the explanation for this trend is that reporting on outcomes rather then inputs and
processes may improve accountability to consumers by increasing the accessibility and
relevance of performance information. The literature also suggests that the lack of
consumer focus in performance measurement may explain the ‘perception gap’ between
consumers and service providers or government agencies. This suggests that reporting
on outcomes of public services may impact on consumer perceptions of those services
(see SCC, 2007, Literature Review on the Consumer Approach to Scrutiny).
Draft Annual Plan 2010-11 for consultation 25
This project will explore to what extent Scottish public services have moved towards
outcome focused reporting of their performance.
The work will include:
analysis of the extent of outcome focused reporting of public service performance through a review of current practice
discussions with stakeholders on current practice
exploration of the views of consumers on current practice through focus groups with consumers
We aim to:
promote robust and outcome focused measurement of Scottish public services
improve reporting of public services performance to consumers and the public
The benefit to consumers will be:
an improved outcome focus within Scottish public services. Services will be designed around their needs and expectations and by providing information to allow them to judge services delivery levels, consumers will be more able to challenge poor quality services
E. Rights, regulation and redress
S9. UK Nutritional Strategies Seminar
A UK Nutritional Strategies seminar with representatives from Scotland, England, Wales
and Northern Ireland will discuss how nutrition strategies have been created and applied
and whether they are working in the consumer interest. Invitees will include Consumer
Focus, Food Standards Agency and Government representatives from each country
together with World Health Organisation (WHO), EU Commission, Community Food and
Health Scotland, healthyliving award and BEUC.
It is important that the consumer voice is heard in the development of nutritional
strategies as a counter to the food industry. The UK Nutritional Strategies seminar would
enable the exchange of ideas and focus on the consumer.
We seek:
improved relationships, communications and understanding of different UK strategies together with knowledge of good practice that could be utilised elsewhere. A deeper appreciation of the consumer view by Governments
The benefit to consumers will be:
the development of nutritional strategies that reflect the consumer voice (particularly the disadvantaged)
S10. Care preferences in old age
Care services for older people have, in the past, been provided in ways which do not
necessarily cater well for individual choices. Today’s 50 and 60-year-olds are likely to
have different expectations about the kind of care or support they would like if or when
they are no longer able to live independently.
Draft Annual Plan 2010-11 for consultation 26
Current policy emphasises the desirability of providing personalised care services.
However, economic pressures, and pressures associated with an ageing population may
mean that it is harder to provide the diversity of service models which would be required
by genuinely personalised services. There is evidence that policies such as Direct
Payments, which are an example of allowing service users to purchase their own care
‘package’ have a very low level of use. The reasons for this may be complex, but are
likely to include local authorities not encouraging or facilitating uptake.
For personalisation to be a reality, policy makers and service planners need evidence
supporting the range of needs and preferences of future consumers in relation to care
and support services. This may include things like housing preferences and alternative
models of supported living.
We aim to:
provide an evidence base which will influence policy and service provision in this area in the future. This should provide a greater range of options and choices for older people in need of support for independent living, based on evidence of what people want
S11. Contributing a low-income consumer viewpoint to the sustainable development debate
There is increasing clarity and agreement over long-term environmental and sustainability
policy aims across a range of issues, many of which are now linked to the climate change
agenda2.
Debate is now focusing on the means by which these aims can be achieved, and change
in consumer behaviour is frequently highlighted, explicitly or implicitly, as part of the
overall solution.
This work will define and represent a consistent low-income consumer viewpoint in
debates around sustainable development as they progress in Scotland, taking forward
the findings of 09/10 research on tensions and opportunities between the environmental
and consumer perspectives, and building on existing work on climate change, recycling
and microgeneration.
We seek to ensure that:
low income consumer viewpoints are considered and represented as an integral part of all debates which involve changes in the goods and services people use
The benefit to consumers will be:
sustainable development strategies for Scotland to take account of the limited environmental impact of low-income consumers and emphasise the social and economic aspects of sustainable development
2 An outline of the issues covered in the Act and links to the full text and associated strategies are
available at http://www.scotland.gov.uk/Topics/Environment/climatechange/scotlands-action/climatechangeact
Draft Annual Plan 2010-11 for consultation 27
S12. Freedom of Information five years on: the impact on consumers
The Scottish Consumer Council had a long history of work in relation to Freedom of
Information and in 2007, in conjunction with the Scottish Information Commissioner,
published a guide for consumers on their rights to access information under the Freedom
of Information (Scotland) Act 2002 called ‘Your Right to Know.’ Having campaigned for
the right of access to information for campaigners, we are keen to undertake work
exploring the practical impact of this legislation on consumers.
This research will explore the impact of this legislation on consumers, including for
example:
are consumers making use of FOI provisions? If not, why not?
what are consumers using FOI for?
are consumers being provided with the information they request and within the appropriate timescales?
what do consumers think about the current processes?
do consumers want to obtain information from organisations that are not subject to FOI and are therefore unable to obtain such information?
We will undertake research into the impact of the Freedom of Information (Scotland) Act 2002 on consumers.
We aim to ensure that:
organisations apply the legislation correctly and consistently. Consumers to make greater use of the process, confident in the quality of responses they receive
The benefit to consumers will be:
receiving the full benefit of the legislation and having confidence in the process
S13. Civil Justice
We will undertake a range of activities under the broad principle of improving consumers’
access to civil justice, including work on class actions, court users and administrative
justice. The direction of our work on civil justice will depend largely on what
recommendations emerge from the civil courts review, published on 30 September 2009,
and the Scottish Government's response to the recommendations of the Administrative
Justice Steering Group's recent reports.
It is important that the civil justice system focuses on the needs of those who use it. The
present court system is too focused on the needs of lawyers rather than on the needs of
the ultimate users of the system, ie those who become involved in civil disputes. At
present, court processes can be confusing, intimidating and even frightening for parties,
particularly those who are unrepresented. In those cases where they actually get as far
as the hearing, unrepresented litigants are very often faced with a solicitor representing
the other side, within an intimidating and formal setting dominated by lawyers wearing
formal dress and using legal language. We have long been concerned that this places
unrepresented litigants at a potential disadvantage in court proceedings and indeed may
deter people from pursuing legal action.
Draft Annual Plan 2010-11 for consultation 28
We seek:
To improve access to justice for consumers. We believe there is a need for a four step approach to remove the present barriers to access to justice within the civil justice system:
a public legal education strategy
coherent and appropriate advice services
an emphasis on informal means of resolving disputes
user-friendly formal dispute resolution mechanisms
The benefit to consumers will be:
The overall benefit to consumers of these strands of work is increased access to justice
S14. Public Legal Education
The Paths to Justice Scotland research found that one in four people in Scotland had
experienced one or more justiciable problems during the previous five years,
considerably fewer than the proportion of those who say they have had justice problems
in other countries. If someone does not recognise they have a problem, they will not know
they need to take steps to deal with that problem, let alone what steps they should take.
Even among those who recognise they have a dispute, some take no action to resolve it.
The available evidence suggests it is likely that people do not seek advice because they
do not know where to go for help.
The report of the SCC’s Civil Justice Advisory Group concluded that there is a need for
improved public legal education about the civil justice system and basic social and legal
rights and responsibilities, targeting hard-to-reach groups in particular. This has recently
been supported by our research into the views and experiences of civil sheriff court
users. From the research, there emerged a clear need for greater provision of practical
and comprehensive information for litigants on what to expect during legal proceedings,
and how litigants can best seek advice and progress their case effectively.
This work will involve a quantitative survey to ascertain consumers’ level of knowledge of their legal rights, responsibilities and means of redress in relation to a wide range of problems with a potentially legal solution.
We seek to ensure that:
public legal education is seen as an important and integral part of the legal assistance given to consumers, with a strategic approach taken to this area’s development
The benefit to consumers will be:
improved, targeted public legal education would empower consumers and ensure they are better informed about their rights and where to seek help and advice. This would ensure that consumers have better access to justice than at present
Draft Annual Plan 2010-11 for consultation 29
S15. Lunching out
This work follows on the 2008 SCC research report ‘Out to Lunch’, which examined the
lunchtime choices of pupils who regularly choose not to eat school dinners but instead
prefer to purchase food out of school. This work will be based on the report
recommendations and will promote links with other initiatives such as the healthyliving
award and the neighbourhood shops project. It will involve working with young people,
staff, retailers and the wider community. Scottish Government will be on the Advisory
Group for the work and will be involved in issues and solutions as they arise. The final
research report will inform their work in this area. Consumer Focus Scotland can use the
findings to illustrate how to take this work forward.
The benefit to consumers will be:
improved lunch time choices for pupils who do not eat school lunches and improved offerings from retailers for the local community
S16. Test case on Land Owning Maintenance Companies
Following a recommendation from the OFT in February 2009, this work will support a
group of owners to test the provisions of the Title Conditions (Scotland) Act 2003 in
regard to dismissing land-owning maintenance companies and appointing alternative
providers. This work is likely to consist of both practical support to a group of owners and
financial support to access legal services.
The legal ruling will either:
empower consumers to use the provisions in the Title Conditions (Scotland) Act 2003 to dismiss their existing provider of land maintenance and appoint an alternative provider
highlight a gap in existing legislation that Consumer Focus Scotland will use to campaign for a change in the law to enable owners to choose an alternative land-owning maintenance company
The benefit to consumers will be:
in the longer term, the ability to choose their provider should increase competition for consumers and lead to better quality of service
S17. Digital consumers in Scotland
Communications markets, including those for broadband, television, radio and mobile
phones, are of critical importance to Scotland particularly in relation to universal services
and digital inclusion. Access to an effective communications network is an economic and
social lifeline, and a clear necessity if people are to participate properly in modern
society. Yet consumers in Scotland often face particular challenges and barriers that can
hinder their ability to operate successfully in these markets.
This applies in both rural and urban areas. The situation for Scottish consumers is further
complicated by the fact that the Scottish Government has certain devolved powers in
these areas, but many issues are taken forward at UK level. This work will look at how
markets and policy can best function in this context to achieve the best outcomes for
Scottish consumers.
We will produce a strategic policy paper on the communications sector for consumers in
Scotland. The strategy paper itself will identify the key changes that are required and will
identify how these might be achieved.
Draft Annual Plan 2010-11 for consultation 30
The paper will also serve as a useful base for determining how Consumer Focus
Scotland responds to new policy developments in different communications markets, and
provide a valuable framework for identifying what changes might be required in relation to
these developments.
The benefit to consumers will be:
the strategy paper will benefit consumers as it will identify key issues and areas of detriment for Scottish consumers, and set out Consumer Focus Scotland’s views on these issues. This will place Consumer Focus Scotland in a stronger position to work with stakeholders to achieve change for the benefit of consumers
S18. Consumers and the economy in Scotland
Many of the markets where policy responsibility is reserved are broadly similar across the
UK. However there are often important differences between Scotland and other parts of
the UK in these markets in relation to key consumer issues such as access, choice and
fairness. While policy may be the same throughout GB, the delivery mechanisms may be
very different in Scotland – for example while consumer protection laws may be broadly
the same but the legal system and courts through which those laws might be enforced
are entirely different, and policy responsibility for those institutions is devolved to the
Scottish Government. Therefore there must be clear routes and mechanisms through
which the specific interests and concerns of Scottish consumers in these markets are
identified, responded to and addressed.
This paper will build on Consumer Focus Scotland’s previous work in this area and will
promote the need for the consumer voice to be given an appropriate platform in all
debates on policy and markets in Scotland.
We seek:
we want the consumer interest to be embedded within all debates around policy and markets in Scotland, so that it is given equal weight to the legitimate interests of business and of organised labour
The benefit to consumers will be:
the consumer interest will be given greater prominence and a more central role in the policy making process, leading to a reduction in consumer detriment across a range of different markets
Draft Annual Plan 2010-11 for consultation 31
Consumer Focus Wales
In Wales, projects are represented within two strands:
Representing consumers
Empowering consumers
W1. Driving forward the fuel poverty agenda in Wales
Representing consumers
There are now around 320,000 households in Wales (one in four) in fuel poverty,
categorised by the combined effects of poor energy efficiency of homes, low incomes and
high energy prices3.
We will work in partnership with others to ensure that fuel poverty is kept high on the
political agenda in Wales and campaign to see the policy priorities outlined in the Fuel
Poverty Charter become a reality.
We will achieve this via the Cross Party Group on Fuel Poverty; by driving forward policy
calls in the Fuel Poverty Charter through the Wales Fuel Poverty Coalition; as part of the
Ministerial Advisory Group on Fuel Poverty and by undertaking our own campaigning and
lobbying on this issue.
Impact
we want to see a fuel poverty strategy for Wales that is fit for purpose and provides a framework for removing vulnerable consumers in Wales from fuel poverty. Our Charter calls for action by the Welsh Assembly Government, UK Government, Ofgem, local authorities and energy companies
we will identify where and who consumers in fuel poverty are, so that they will receive appropriate, co-ordinated help and support to bring them out, and keep them out, of fuel poverty
W2. Impacts of fuel poverty and fuel debt for consumers in Wales
Representing consumers
Fuel poverty contributes to a wide range of other detriments, including poor mental and
physical health, reduced quality of life, restricted educational attainment, social isolation
and indebtedness4.
This project will highlight the impacts that living in fuel poverty has on individuals and
households. We will follow the stories of people who are in this situation and record the
personal impact. We will highlight the issues experienced by consumers, how suppliers
respond to their needs and explore the impact that not being able to afford to pay for fuel
has on consumers' health.
3 NEA Cymru estimate, 2009
4 Research by NEA Cymru
Draft Annual Plan 2010-11 for consultation 32
Impact
aside from the debate on cost and debt we feel that it is important that the impact that this situation has on people's health and wellbeing is recognised and that suppliers and the regulator work to avoid negative effects
as well as improvement in the practices of energy suppliers and the regulator, we want the effects of fuel poverty to be recognised as more far-reaching than simply a monetary issue. We would like to see consumers seeking support at an early stage, to prevent some of the wider effects taking hold, and improved support for these consumers provided by suppliers
W3. Pricing and switching phase II
Representing consumers
This project will further examine the low rates of energy company switching in Wales.
It will build on the findings of our current work on pricing and switching, which is looking at
some of the reasons behind the characteristics of the market in Wales, including the high
price of electricity.
According to Ofgem, ‘the Scottish and Welsh markets exhibit some distinct
characteristics. They are the most concentrated markets in Great Britain, with the
combined market share of the former electricity incumbent and British Gas exceeding 80
per cent in the south of Wales region’.
UK Government figures published in March 2009 show that 86 per cent of pre-payment
meter consumers in south Wales remain with their in-area supplier (the local incumbent
supplier) compared to a British average of 48 per cent.
We will look at developments in the Welsh consumer energy retail market in the context
of Ofgem’s Retail Remedies, which will start to affect consumers from autumn 2009. One
of the aims of the Retail Remedies is to make market competition more effective by
improving the information provided to customers.
Impact
by understanding the reasons for consumer behaviour and ensuring that information is better tailored to their needs, we will encourage Welsh consumers to be more active in energy markets, so that the market for consumers in Wales becomes more competitive in terms of cost and customer experience
W4. Off gas network consumers in Wales phase II
Representing consumers
According to the Welsh Assembly Government’s ‘Living in Wales’ survey5, 30 per cent of
households that are not connected to the mains gas network (referred to as ‘off gas’) are
in fuel poverty compared to seven per cent of those ‘on gas’.
The Better Regulation Executive6 reports that 25 per cent of Welsh households are off
gas, compared to 17 per cent in England.
We will undertake research looking at the detriment faced by consumers in Wales who
are ‘off gas’ and who have to rely on LPG or other forms of heating and energy. We will
look at issues including fuel efficiency, switching suppliers, bulk buying groups, regulatory
intervention, mains gas connection and micro-generation.
5 Living in Wales 2004
6 2007
Draft Annual Plan 2010-11 for consultation 33
This work will build upon the work we are currently doing both in Wales and at a UK level
to give us an evidence base of the demographics of who is and is not connected to the
network and what effect it has on their lives.
Impact
we want to see that suppliers understand and react to consumer need and experience. We also want to look at how communities might be empowered to take control of their own energy supply choices, including taking steps to access the gas network
this work would also be used to influence Welsh Assembly Government and local government policy from an evidence base that provides a consumer perspective
this project may lead to the development of better information to consumers on tackling the detriment they face from being ‘off gas’, with the goal to ultimately empower people to collectively and individually understand and make best use of the energy options available to them
W5. Pre-payment meters Wales phase II
Representing consumers
The recent Ofgem Energy Supply probe found that there is above average use of pre-
payment meters in Wales. Furthermore, UK figures7 show that 26 per cent of fuel poor
households and 37 per cent of people living in social housing pay by pre-payment
meters.
We will look in detail at the difficulties faced by consumers using a pre-payment meter. As
well as self disconnection, known issues include the availability of retail points for key
cards, levels of debt on bills, location of meter, low levels of switching, debt blocking and
cost of energy.
This follows on from our current work on pre-payment meters and self disconnection.
Impact
we want to improve services for consumers by helping energy suppliers and energy keycard retailers build their policies on the real life experiences of consumers. We also want to see an improvement in the information for consumers, particularly regarding their rights
Fair deal for postal consumers
W6. Pushing the envelope – innovation and diversification of post office services in Wales
Representing consumers
The Post Office network provides access to essential financial services such as cash,
benefits and pensions, as well as mail services. Exploring ways of how the network can
innovate and diversify in the services that it provides is an important way of providing
better access for consumers and bolstering the network.
7 Ofgem Probe, 2008
Draft Annual Plan 2010-11 for consultation 34
The Welsh Assembly Government has made a commitment to play its role in supporting
the network for the lifetime of this administration. It recognises the social and community
value of post offices especially in supporting vulnerable people in Wales’ most isolated
and disadvantaged communities and in tackling financial inclusion.
We will undertake research into what innovative ways of providing local authority and
community services in post offices currently exist and then work with others to
disseminate best practice.
We want to provide examples of how local authorities could provide services through post
offices; and for sub postmasters to consider how they might use the Welsh Assembly
Government's Post Office Diversification Fund to diversify the services they provide,
meeting consumers’ needs and benefitting the community.
Impact
at its most basic this work would help promote the long term viability of the network. It would also lead to provision of a range of services that better meet consumer needs delivered at the post office
W7. Monitor and evaluate the provision and quality of post office services in Wales.
Representing consumers
We will undertake further research on post office usage by consumers in Wales, their
views about the quality of post office services and their overall post office experience. In
particular we are keen to understand the experience of consumers in rural areas,
deprived urban areas, those on low incomes, the elderly, disabled people and those with
young children.
This work would be a continuation of work from our current workplan and part of our
statutory duty to represent consumers in relation to postal services.
We will share the findings with stakeholders such as Post Office Limited, the UK
Government and the Welsh Assembly Government to help their understanding of post
office provision in Wales, how well it meets consumer need and improvements that could
be made.
Impact
consumers who use post offices in Wales will have a voice. We will use that voice to lobby key stakeholders to achieve change in any areas which cause detriment
we want to support consumers who use post offices in Wales to have a voice in how they receive services and to communicate their experience
we will lobby Post Office Ltd, the Welsh Assembly Government and the UK Government when we find areas that cause detriment to consumers and where an improvement in the quality of service provided would result in consumers becoming more likely to use these services
Draft Annual Plan 2010-11 for consultation 35
W8. Royal Mail Delivery Services and consumer rights (including micro-businesses)
Empowering consumers
Discussions with stakeholders suggest that there are a number of issues with Royal
Mail’s current Parcel Delivery Service. These include the distances some customers must
travel to get to a post office or sorting office to pick up and post items, the practice of
doorstepping (where parcels are left on doorsteps when no one is home) and the amount
of lost, missing or stolen post.
As part of the recent Post Office closure programme, 150 urban and rural post offices
closed in Wales, replaced by 59 outreach services. This has a big impact on consumers
and micro-businesses, particularly in those areas where consumers or businesses have
to travel further to post an item or pick up a delivery.
We will highlight examples of good practice and good design which improve the system
for users, in order to advocate for improved services and identify which parts of the
service are failing consumers and businesses. We will also work with Royal Mail to try
and identify any further potential service improvements.
Furthermore, we will develop an information campaign to raise consumers’ awareness of
their rights in relation to deliveries.
Impact
we want to help ensure that the Royal Mail delivery service meets the needs of consumers and micro-businesses, of which there are a high number in Wales, many based in rural areas. Good practice models that benefit consumers will be identified, publicised and adopted more widely
Fair deal in financial services
W9. Financial advice for young people
Representing consumers
Since September 2008 personal finance education has had an enhanced position on both
the primary and secondary school curriculum in Wales, recognising the importance of
improving and developing financial inclusion to the social justice agenda.
However research8 tells us that half of 16-34 year olds in Wales learn about money
issues from their parents or another family member/guardian. We also know that the
accuracy and relevance of the information received is likely to vary from family to family.
Without the right knowledge and skills to manage their money effectively many young
people may make poorly informed financial decisions.
This could result in the purchase or use of costly, inappropriate or unnecessary financial
products, or a greater likelihood of them getting into unmanageable debt.
This project will look at the awareness and understanding that young people (aged
between seven and 18) have of financial issues, what types of information they value and
how existing information channels could be extended and improved.
We are seeking to extend and improve what is available for teaching young people about
financial issues, based on what young people tell us they value and need.
8 ‘Figuring out finance’, Welsh Consumer Council, Nov 2005
Draft Annual Plan 2010-11 for consultation 36
Impact
an increased understanding of the views and experiences of young people will help to ensure that the information they receive is clear, relevant, properly targeted and effective. Ultimately this will help them to help themselves. The financial world and the products within it move at a seemingly ever-increasing rate. Young people need to develop the ability to deal with these changes and to take those skills into their adult lives
the outcomes of this project will build on the financial capability work of the Financial Services Authority in Wales. We will use the views expressed directly by young people to influence the UK Government’s Money Guidance project and the work of the Welsh Assembly Government – both directly and via its agencies
W10. Tracking over-indebtedness in Wales
Representing consumers
With many people now facing redundancy and unemployment and essential living costs,
such as energy and other household bills, continuing to soar, it is likely that many
consumers will be struggling to manage their finances in the coming months and possibly
years.
Citizens Advice Cymru has reported that debt-related issues accounted for the highest
number of queries to bureaux in Wales between April 2008 and April 2009.
There is a need to assess the impact that the current recession is having on the ‘financial
health’ of consumers in Wales, particularly those threatened with redundancy, reduced
working hours, or with high levels of existing debt, to provide an evidence base for any
policy decisions aimed at supporting those who need help.
In this project we will undertake research to examine the types of credit held, people’s
ability to manage those credit commitments, how likely they are to fail to make payments
and the implications for the Welsh Assembly Government’s financial inclusion policies.
Impact
our work in this area has already been cited by the Welsh Assembly Government in their Financial Inclusion Strategy. This new work will enable us to ensure that their policies to tackle debt and financial inclusion reflect the needs and priorities of consumers in Wales, and in particular that adequate, and correctly targeted services are in place to help people
W11. Financial service jargon
Representing consumers
Research and experience tells us that people find financial information difficult enough to
understand at the best of times. We are now in a time when people’s financial decision
making may have profound effects on both their short and long term financial health.
We want to ensure that financial institutions provide consumers with clear information in
all their financial products and to highlight how poor communication can contribute to bad
financial decision making.
We will encourage consumers to share their examples of ‘gobbledygook’ in the financial
service sector with us. We will do this via our website and by targeting media and
stakeholders.
We intend to put together a panel of experts to assess the examples and we will then
publish the five worst offenders.
Draft Annual Plan 2010-11 for consultation 37
Impact
an inability to understand what the other party is saying renders any of us powerless in a conversation
if, by being named and shamed, financial institutions change their policies and improve the clarity of their products, consumers’ understanding and ability to make better choices will improve
W12. Switching financial services
Empowering consumers
We have seen a significant increase in numbers of price comparison websites in recent
years, designed to help people exercise their power to choose by switching in key
product/service areas, most notably in the financial and utility sectors.
The result has been fierce online market competition as providers work hard to entice
customers to choose their products. However, for those who do not use the internet,
either by choice or by lack of access or ability, switching providers can be a much more
daunting and complicated process.
Recent research by Consumer Focus Wales found that 31 per cent of consumers in
Wales do not use the internet, rising to nearly half of social categories DE (46 per cent)
and almost three-quarters of those aged 65+ (73 per cent).
In this project we will examine the extent to which consumers in Wales actively engage in
the financial services market.
We will look at the levels of switching in key aspects of the market, as well as consumers’
confidence in switching, how easy they find the process, their information needs, any
perceived barriers to switching, and what impact, if any, the economic downturn has had
on their switching behaviours.
Impact
we want to achieve a situation where consumers who want to switch, will feel knowledgeable and confident in the switching process and able to find products that are appropriate to their needs and circumstances
we will try to find solutions, such as safe switching guides, to support consumers who want to engage more actively in switching financial services
W13. Older people’s finances, phase II
Empowering consumers
The older population in Wales makes up a large and growing sector of our demography –
around 22 per cent which, according to Age Concern, is higher than the UK average9.
UK-wide data suggests that a small but growing number of older people are reaching
their anticipated retirement age without adequate planning and with existing debts.
For some older people, meeting repayments on these commitments will mean having to
carry on working, or even looking for additional work in order to service these debts. For
many, a pension alone will be insufficient to meet their repayments.
This project aims to provide insight into older people’s finances in Wales, focusing on
levels of debt and borrowing amongst the 65+ age group, and will build on our current
work in this area.
9 A statistical focus on older people in Wales, National Statistics Office and Welsh Assembly
Government, 2008
Draft Annual Plan 2010-11 for consultation 38
Impact
ultimately we want to see provision of advice and support services based on older people’s needs and wants, along with early intervention of support services to prevent further detriment
we believe that improving the amount and timing of appropriate advice and information can lead to more informed and empowered consumers. In this way, those who want and are able to look after themselves are enabled and those who need further support are identified
Consumers and public services
W14. Use of bailiffs by local authorities
Representing consumers
Last year Welsh local authorities were unable to collect £37 million of Council Tax
charges10.
Part of the standard procedure for recovery of unpaid debt is to employ bailiffs who will
make approaches to the debtor using methods which are, at present, ungoverned by
regulation.
We want to investigate bailiff practice from a consumer perspective, providing qualitative
evidence of any need for industry-wide independent regulation.
Bailiffs are deployed to recover many different types of debt. This project will focus on the
use of bailiffs by local authorities in Wales.
Citizens Advice has done a lot of work in this area and has worked with the Local
Government Association to produce a good practice protocol for collection of Council Tax
arrears in England and Wales.
Citizens Advice is continuing to work in this area but there is scope for us to work with
them to add value to this work by not only encouraging adoption of best practice but also
providing an evidence base on which to evaluate the effectiveness of proposed
regulation.
Issues to be explored include:
potential tighter regulation of the bailiff industry
a statutory code of conduct and complaints procedure
better scrutiny of local authorities’ contracts with bailiffs
caps on bailiff charges
whether local authorities should use in-house bailiffs in preference to contracted private bailiffs
Impact
if necessary, we want to see tighter regulation of the bailiff industry, as well as detailed best practice guides by the Welsh Assembly Government
the results of this should lead to consumers who fall into Council Tax arrears, Housing Benefit arrears or, as social tenants, into rent arrears, not having to face
10
Welsh Assembly Government Council Tax Collection Rates 2008-09
Draft Annual Plan 2010-11 for consultation 39
additional, unnecessary stress from private bailiffs behaving without a code of conduct
furthermore, they would not face bailiff charges on top of their debt burden, making the situation even worse. We would want to see these consumers offered alternative debt solutions based on co-operation and mutual agreement, involving independent advice and advocacy, with bailiffs deployed as an absolute last resort
Rights, regulation and redress
W15. E.coli – learning the lessons
Representing consumers
In March 2009, Professor Hugh Pennington presented his inquiry report to the Welsh
Assembly Government. The report made 24 recommendations aimed at preventing
another outbreak of e.coli 0157, not just in Wales but in the UK as a whole. It was
welcomed by all parties, including the families of those affected by the South Wales
outbreak. Work has now begun to implement the recommendations.
Our work in this area began in this current workplan year. There are two strands, firstly
working with the families, the Food Standards Agency, Welsh Assembly Government and
the Welsh Local Government Association and other stakeholders to track the
implementation of the Pennington report’s recommendations and to keep consumers
updated on progress. The other is working with the Food Standards Agency to ensure
that consumers have access to information about the hygiene ratings of food businesses
in Wales.
We envisage that there will now be ongoing bi-annual meetings to track the
implementation of the recommendations.
Furthermore, we have been invited to be part of the Food Standards Agency’s Wales
Steering Group for their ‘scores on the doors’ consumer information work. Our research
has already indicated that nine out of ten consumers want access to this information.
Impact
consumers cannot undertake hygiene tests themselves before they make decisions on where and what to eat. Instead they put their faith in the systems set up to protect them and those in positions to represent them
all stakeholders in the group are dedicated to ensuring all necessary steps are taken to prevent another major outbreak of e.coli 0157 in Wales. The group will ensure that progress towards this goal is transparent for consumers
additionally, by giving consumers greater access to the outcome of those systems – food hygiene ratings, we can empower them to make their own, informed decisions about where they eat, and what they consider to be acceptable
Draft Annual Plan 2010-11 for consultation 40
W16. Service quality in Housing Benefit administration
Representing consumers
In 2007-08 there were 165,077 new Housing Benefit claims made in Wales, taking the
total number of Housing Benefit claimants in 2007/08 to 304,61211.
Housing advice agencies – Shelter Cymru, Citizens Advice and the Welsh Tenants
Federation – report that faults with the administration of Housing Benefit are some of the
most frequent and recurrent problems they come across.
This project will find out what people really experience when they make a claim for
Housing Benefit.
There has been little research to explore the extent and nature of the problem in Wales
and importantly the resulting psychological effect of waiting in financial limbo for a
Housing Benefit decision – the knock-on health implications of the stress of financial
uncertainty, possible harassment from landlords and the reality of homelessness.
While work is happening at a grassroots level to support consumers to resolve their
Housing Benefit problems, there is little work currently being undertaken at strategic level
either with local authorities or the Welsh Assembly Government to improve practice.
Consumer Focus Wales proposes working in partnership with those with expertise in this
area, to campaign for a better deal for Housing Benefit claimants in Wales.
The research findings from this work will provide an evidence base for our discussions
with policymakers with a view to promoting best practice among local authorities in
Wales.
Impact
there are opportunities to make an impact in this area as, although Housing Benefit is not a devolved issue, the Welsh Assembly Government still has a clear role in terms of co-ordinating and guiding local authority performance on the administration and processing of Housing Benefit
our findings will feed into the implementation plan of the Welsh Assembly Government's 10-year Homeless Strategy12, by recommending the precise ways in which Housing Benefit administration performance needs to be improved
for Housing Benefit claimants, this would lead to a greater focus on their experience and needs, minimising additional stress
W17. Consumers and the Welsh Language
Empowering consumers
The number of people speaking and learning the Welsh language has increased in recent
years; today approx 200,000 people are learning the language13. Many of these are
young people in school, therefore in addition to the numbers of consumers speaking
Welsh now there is likely to be an increase in the number of consumers in the future who
may wish to use services through the medium of Welsh.
11
Local Government Data Unit Performance Indicators 2007/08: BNF/002a; BNF/001cD 12
Welsh Assembly Government Homeless Strategy 2009-2019 13
Welsh Assembly Government, Welsh Language LCO Q&A
Draft Annual Plan 2010-11 for consultation 41
During this current workplan year we are undertaking research to identify the key issues
for Welsh speaking consumers. This project will build on that work, presenting an
evidence base to ensure the consumer voice is heard in the development of new
legislation.
We want consumers to have a voice at the heart of decisions about the services they
should be able to access through the medium of Welsh, the standard of those services
and what form they should take.
Impact
greater clarity as to what consumers can expect in terms of Welsh medium services and that, where an organisation is not meeting its responsibilities (voluntary or statutory), consumers have a clear right and route of redress
we would also like to move the parameters of the Welsh language debate to consider ‘what consumers would want’ as well as ‘what consumers have a right to’
W18. Shoppers’ rights
Empowering consumers
We will undertake a campaign to raise awareness of shoppers’ rights, inspired by work of
the Consumer Council of Northern Ireland who regularly run information and education
campaigns.
They have distributed over 150,000 Shoppers’ Rights Cards – a credit card sized
reminder of any shoppers’ basic rights and responsibilities – since their launch in 2003.
We will produce and promote our own bilingual Shoppers’ Rights Card and look at on-line
mechanisms for delivering similar information to on-line shoppers.
We will look to learn lessons from the Consumer Council’s other communications
campaigns, such as the receipts wallet – distributed at Christmas to encourage
consumers to understand and exercise their rights when returning goods, or the
Christmas dinner budget planner designed to help minimise unnecessary spending and
food waste.
Impact
to give consumers a greater knowledge of, and confidence in, their rights and responsibilities, in a practical, convenient and easily accessible format. As a consequence, we hope to improve the reaction of retailers in response to consumers seeking to exercise their rights
some consumers will benefit directly from receiving a card. Others should benefit indirectly from a greater awareness among retailers of their customers’ rights
W19. Understanding the experiences of children and young people as consumers in Wales
Empowering consumers
There is currently no legislation to protect children and young people from being
discriminated against in accessing goods and services.
Anecdotally, it is acknowledged by those working with and representing children in Wales
that children and young people in Wales are often disadvantaged in the way that they are
treated when using services. This project seeks to unearth such examples, draw attention
to these and highlight where appropriate the need to uphold the rights of children and
young people as consumers in Wales.
Draft Annual Plan 2010-11 for consultation 42
We will look at how young people are able to access services; attitudes of service
providers towards young people as consumers; young people’s understanding of their
rights as consumers and how effective and appropriate existing redress mechanisms are
for this group.
We will highlight any evidence of discrimination and disadvantage within a selection of
services and markets, as identified through work with young people themselves.
Impact
having recently gained legislative competence over children’s social policy in Wales, the Welsh Assembly Government is considering putting the core objectives of the UN Convention on the Rights of the Child into Welsh legislation
this provides an opportunity to encourage the Welsh Assembly Government to use their influence to address any issues highlighted by this project. There may also be specific elements identified as a result of this work that could feed into a future measure
we will work with others to encourage children and young people to consider themselves as consumers and think about how they access goods and services, their rights and how to seek redress where appropriate
Draft Annual Plan 2010-11 for consultation 43
Consumer Focus Post
B. A fair deal for postal consumers
P1. Managing and developing the relationship between Consumer Focus Post and the Consumer Council for Northern Ireland
Consumer Focus Post (NI) endeavours to work closely with the Consumer Council for
Northern Ireland by developing co-operative working relationships, looking for areas of
synergy between respective work programmes, seeking opportunities for joint working on
specific projects and, where appropriate, carrying out joint staff training and procurement.
We aim to:
help ensure that the Royal Mail delivery service meets the needs of consumers and micro-businesses, of which there are a high number in Northern Ireland, many based in rural areas. Good practice models that benefit consumers will be identified, publicised and adopted more widely
These impacts would enable us to:
strengthen our campaigns and our ability to lobby Government, so improving Post Office services for consumers
P2. Improving mail services for Northern Ireland consumers
To ensure that Northern Ireland mail consumers have a reliable and cost-effective
service. We will: use our research into the performance of the first class mail service
between NI and GB, and between NI and the Republic of Ireland, to campaign for
improved services; carry out an annual survey into the satisfaction levels of NI mail
customers; hold briefing sessions for advice agencies to clarify the complaints
procedures for postal services; provide support on developments regarding the Postal
Services Bill, the Universal Service Obligation and the next Price Control; explore the
level of postal consumers’ discontent with wrongly delivered mail; explore the value
consumers place on their local Callers Office and assess their appetite for alternative
solutions to mail delivery in NI.
We seek:
improved policy and practice – in pursuit of better performance and better value for money for the consumer
a consistent and reliable service, especially between non-metropolitan destinations
a better public understanding of standard mail performance and its charging structure; a better service to communities, especially those close to the border, and to SMEs and micro-businesses engaged in cross-border business
better informed advice agencies which are able to handle public enquiries
improved mail service representing value for money
reduction in the level of complaints for wrongly delivered mail
increased delivery convenience
Draft Annual Plan 2010-11 for consultation 44
These impacts would enable us to:
draw attention (through lobbying and media campaigns) to areas of postal detriment to ensure an efficient and reliable postal service
P3. Maintaining and developing a stable Post Office network in Northern Ireland
Ensuring there is a stable and accessible Post Office network throughout Northern
Ireland, catering in particular for the needs of the vulnerable and disadvantaged in rural
and deprived areas. We will: examine the impact of Outreach Services introduced under
the Network Change Programme; investigate the extent to which NI local authorities plan
to use Post Offices for transactions with their customers; explore the opportunities for
joint working between the Credit Union movement in NI and the PO network; carry out an
annual survey on services, assessing performance; contribute to the work of Consumer
Council for Northern Ireland by encouraging additional free use of ATMs in rural areas,
especially in the Post Office network; provide support to the Communities and Public
Service team in the complaints procedures under the ‘Business as Usual’ consultation
code of conduct; undertake a mystery shopping exercise to ascertain the customer
experience of the branch network.
We aim to achieve:
improvements to Outreach services, as identified through our research
enabling local politicians to engage on Post Office issues as they arise on the UK agenda
well informed local councils that are keen to ensure the sustainability of the post office network in their area
financial incentives and support for the network from central and local government
Post Office consumers are placed at the forefront of central and local government policy changes
a commitment to provide an accessible, customer-friendly branch network
satisfactory resolution to complaints cases which suggest Post Office Limited has not adhered to the code of practice
These impacts would enable us to:
help Post Office Limited achieve a stable and accessible network which meets the needs of communities, in particular the vulnerable and disadvantaged, especially those living in rural and deprived areas
Draft Annual Plan 2010-11 for consultation 45
Supporting and empowering consumers
Consumer Focus’s work is not just about influencing Governments and regulators and
improving consumer service – we also want to support and empower individual
consumers.
If the proposal for a Consumer Advocate in the Government White Paper ‘A Better Deal
for Consumers: Delivering Real Help Now and Change for the Future’ goes ahead, one of
the first tasks is likely to be a review of the provision and effectiveness of consumer
information and education by business and government agencies. We would wish to
extend that to issues of active consumer empowerment more generally.
Consumer Focus also has very specific responsibilities to provide direct individual
support to vulnerable consumers of energy and postal services – largely carried out by
our Extra Help Unit.
Extra Help Unit (EHU)
The EHU assists vulnerable consumers across Great Britain with their energy and postal
complaints. It is managed by Consumer Focus Scotland. Consumer Focus has a
statutory duty to investigate cases where a consumer has been disconnected, is
threatened with disconnection, or has experienced a failure in a prepayment meter
system. Consumers are defined as vulnerable when they are unable to resolve a
complaint for themselves due to their personal circumstances, the urgency of the
situation or the complexity of the case. Consumers are referred to the EHU through
agreed channels including Consumer Direct, Ofgem and the statutory Redress Schemes.
The Executive Liaison Team (ELT) works within the EHU to handle high level
correspondence and referrals from Members of Parliament, Members of the Scottish
Parliament and Welsh Assembly Government Members. The ELT also provides an ‘Ask
the Adviser’ telephone based service to advice agencies seeking assistance on how to
progress their client’s complaint.
The majority of consumers transferred to the EHU are very distressed, on low incomes
and in desperate need of representation. Many suffer from health problems or long term
illnesses and often there are young children residing in the property to consider.
The EHU is committed to resolving consumer complaints in a timely and effective
manner. In doing so the EHU investigates and uncovers failures in companies’ practices
or policies and highlights the distress caused to consumers. The EHU continually reviews
workloads to ensure resources can be diverted quickly to cases where the consumer has
been disconnected. The EHU also encourages suppliers to take into account the
consumer’s ability to pay and assess consumers’ eligibility for both social tariffs and the
Priority Services Register. Being a small specialised team serving Great Britain, the EHU
is able to quickly identify trends where vulnerable consumers are being disadvantaged.
Draft Annual Plan 2010-11 for consultation 46
Case Study – Disconnection
A consumer’s gas supply had been disconnected due to a gas leak. The energy company advised they
would reconnect the supply the following day, but this never happened. The consumer was contacted
by the energy company a week later and they advised the job would be done soon. The consumer
didn’t hear from the energy company so she started calling them, again she was advised the work
would be completed soon. This situation continued for some weeks with the consumer unaware who to
contact about the matter. The consumer had three young children in the property, who were suffering
from colds at the time.
As soon as the consumer contacted the EHU (via Consumer Direct), our consumer adviser telephoned
the energy company advising that the consumer had been without a gas supply for over a month and
was in a vulnerable household – urging immediate action to be taken. The energy company arranged
an emergency appointment and the gas supply was reconnected the same day. The energy company
apologised for the failure to reconnect the supply following the gas leak advising there was a mix up on
their systems and they thought the job had gone ahead. The energy company awarded the consumer
£1,000 in compensation for failure to provide supply.
In 2010-11, the EHU will:
evaluate its performance against key indicators including consumer benefit and customer satisfaction
be active in identifying issues affecting vulnerable consumers, recommending policy changes, and providing evidence and case studies to support these recommendations
ensure that companies (both energy and post) improve their responsiveness to consumer complaints and tackle the root cause of problems
continue to convene quarterly meetings attended by the ‘Big 6’ energy suppliers and the Energy Retail Association in order to share best practice, and improve operational relationships and processes on handling priority/vulnerable cases
plan how it can achieve continuous improvement in the quality of the service it provides to vulnerable consumers
raise awareness of the services provided by the Executive Liaison Team
Testaments from consumers helped by the EHU:
‘I cannot begin to thank you and your staff for all your hard work. I am so grateful words
fail me’
‘When I read your email I almost cried, your response to my complaint is very heartfelt
and understanding which is something I feel has been lacking’
‘Thank you for your help and assistance in this matter. You were prompt, efficient and
effective and I am appreciative of all your efforts’
‘Just a quick email to say a big thank you for dealing with my case. It had gone on for a
long time and it had affected my health with the stress, headaches and some sleepless
nights’
‘It is so important that Consumer Focus carries on the good work in campaigning for a fair
deal for members of the public who are confused by certain companies. Many, many
thanks to you all’
‘I wanted to pass my thanks to Colin, as I have been trying to resolve matters for three
years’
Draft Annual Plan 2010-11 for consultation 47
Complaints of General Interest unit
The Consumers Estate Agents and Redress Act (CEAR) 2007 gave Consumer Focus the
power to investigate complaints which raise new issues that affect consumers generally
or have an important effect on consumers across the UK. We are creating a new unit,
which will be managed by Consumer Focus Wales, to carry out this work. The unit will
receive referrals from designated external and internal stakeholders who work directly
with, or have knowledge about, the issues that are important to consumers. In
exceptional circumstances the unit will investigate complaints from consumers
themselves.
The team will lead investigations, inquiring into and examining consumer issues, when
appropriate using our statutory powers to obtain information from the public and private
sectors. We will champion the rights of consumers based on the facts and evidence
uncovered. The unit will not replicate or duplicate the work of others but aims to
investigate those complaints where there is a gap and a need. The unit will use the
resources throughout Consumer Focus to campaign for a fairer deal based on the
outcome of the investigations.
The recent Government White Paper ‘A Better Deal for Consumers: Delivering Real Help
Now and Change for the Future’, published in July 2009, proposes appointing a
Consumer Advocate based in Consumer Focus. The Complaints of General Interest Unit
will play a key part providing evidence to the Consumer Advocate.
Consumer Focus Labs
Consumer Focus Labs was established to extend our consumer advocacy program to the
internet by developing innovative websites and tools to make peoples' dealings with
companies fairer, save them money, or keep them informed about products or issues that
are important to them.
Consumer Focus Labs is also charged with opening up Government, local authority and
commercial data, which it considers of importance to the public. To this end, the team
completed test freedom of information requests with various local authorities, as well as
submitting subject access requests to companies such as Tesco Clubcard and Orange to
initiate the release of personal information to customers. The findings of these and all
future requests will be documented and followed-up in the event of wrongful refusals.
Consumer Focus Labs assumed responsibility for the Consumer Focus website strategy
in September 2009, working in partnership with the IT and communications departments
to develop a robust platform delivering maximum value for both users and staff.
Draft Annual Plan 2010-11 for consultation 48
Partnership projects
National Social Marketing Centre (NSMC)
During the next financial year, the NSMC will continue to strengthen social marketing
skills and capacity throughout the English health system, by continuing its research
programme and completing an NHS training plan.
We will reinforce our relationship with the Department of Health by delivering high quality
services on-time and within specified budgets. We will actively seek opportunities to build
social marketing capacity across Government.
An important project will be developing a quality assurance system for social marketing in
England, to ensure public money spent on social marketing provides best value and
maximum impact.
NSMC was set up in 2006 following a national review of health-related campaigns and
social marketing in England. Social marketing’s primary aim is to achieve a particular
‘social good’ as opposed to commercial benefit, with clearly defined behavioural goals.
Community Food and Health (Scotland)
Community Food and Health (Scotland) promotes a
national, strategic focus on low income communities
facing barriers (availability, affordability, culture,
skills) to accessing a healthy diet. The project also
has a complementary operational dimension, adding value to the activities of low income
communities, and those supporting them, in tackling these barriers.
The project was established in 1996 and is funded by the Scottish Government.
In 2010-2011 Community Food and Health (Scotland) will be in the final year of its current
30-month business plan. Therefore, it is expected that the two major overarching factors
in the work programme in 2010-2011 will be successfully completing the delivery of the
current business plan and negotiating a business plan with Government for a further
period.
Key areas of work will include:
encouraging and enabling the unique ability of the community and voluntary sector to reach excluded, disadvantaged and vulnerable communities. It is likely this will involve building on work with homeless people, disabled people, older people, and black and minority ethnic communities
improving the resilience of the community and voluntary sector, taking forward current activity building the capacity of individuals and organisations around social enterprise, evaluation and applied nutrition
Draft Annual Plan 2010-11 for consultation 49
promoting the relevance of the sector to the delivery of identified national food and health priorities within existing and currently evolving Government policies (Healthy Eating, Active Living; National Food and Drink Policy; Maternal and Infant Nutrition Strategy) and the associated outcomes-focused national performance management and planning systems
All these activities will be complemented by the team’s well-established and popular
quarterly newsletter, website, small grant scheme and annual
conference.
healthyliving award
The healthyliving award aims to make it easier for people to know
where to go for healthier food when eating out. Funded by the Scottish
Government, the award makes it easier for people to recognise and
select healthier food.
The healthyliving award recognises an organisation-wide commitment to provide and
support healthier eating, as expressed through the menu; the way in which food is
prepared; the marketing and promotional activities used and the way in which food is
presented and sold. It rewards establishments that are committed to actively and
continuously reducing the amount of fat, salt and sugar in the food they provide and
increasing the provision of fruit and vegetables.
The work plan for 2010-11 will be structured around the following five headings:
1. Engaging with the catering industry – we will continue to engage with the catering industry to encourage participation in the healthyliving award:
2. Engaging with the high street sector – we will actively engage with and promote the award to companies providing food on the high street and to family eateries
3. Addressing health inequalities – we will actively engage with food outlets in low-income communities to make it easier for people to access healthier food choices
4. Marketing and promotion – we will work to increase exposure of the award brand, and to increase brand awareness and recognition among both caterers and consumers
5. Engaging with stakeholders – we will strengthen and develop links with existing and new stakeholders. In addition we will strengthen links with other relevant initiatives, at both local and national level, for example other award schemes, catering initiatives etc, to ensure synergy and a consistency in approach where appropriate
The Scottish Accessible Information Forum (SAIF)
SAIF promotes and provides guidance on the provision of accessible information for disabled people and carers. Established in 1997, it is a Scotland-wide project funded by the Scottish Government with Section 10 funding on a three year cycle. The work of the project is directed by the SAIF advisory body which is made up of disabled people and information providers. Key areas of work for SAIF during 2010/11 will be:
delivering a training programme and responding to requests for in-house training
promoting and meeting demand for the SAIF Standards for Disability Information and Advice Provision in Scotland and the wide range of other SAIF publications
working with local authorities, health services and other public sector bodies to help them implement accessible information policies and strategies
Draft Annual Plan 2010-11 for consultation 50
promoting and maximising use of the new SAIF website
producing regular e-newsletters
promoting an updated Scottish Directory of Alternative Formats Providers
looking to promote and providing guidance for producing easy-read materials
negotiating with quality assurance systems for the inclusion of SAIF Standards
considering organisational and funding options for beyond March 2011 when the current Section 10 grant finishes
Health Rights Information Scotland
Health Rights Information Scotland (HRIS) aims to
produce nationally relevant patient information
products focusing on patients’ rights, and to ensure
that patients and members of the public, as well as
NHS staff, are involved in this process.
HRIS is funded by the Scottish Government, and managed by Consumer Focus Scotland
and its work has been recognised at UK level. At the British Medical Association (BMA)
Patient Information Awards 2009, HRIS’ leaflet ‘Have your say! Your right to be heard’
was awarded a ‘highly commended’ certificate. The panel of judges described the leaflet
as ‘a clearly and attractively produced booklet pitched well at its target audience with
good signposting’. This builds on HRIS’ previous achievement, winning first prize for its
‘Confidentiality – your rights’ leaflet at the same awards ceremony in 2007.
Key activities for 2010/11 will include:
producing, maintaining and updating high quality and consistent information for patients throughout Scotland about their health rights
ensuring accessibility of the information produced, in terms of format, language and style
promoting appropriate patient and public involvement in information production
advising and assisting others in producing good quality information for patients by acting as an effective and accessible resource for those involved in producing patient information throughout the NHS and voluntary sector
Draft Annual Plan 2010-11 for consultation 51
Strengthening our capacity to deliver results
Corporate services
Corporate services support Consumer Focus’s core business activities through the
provision of information technology systems, records management, people management,
financial services, procurement and administrative support. In offering these essential
support functions, the department aims to develop leading business practices that enable
Consumer Focus to effectively deliver the work set out in the Annual Plan.
In addition to our specific work proposals and progress on corporate services, Consumer
Focus plans a number of cross-cutting organisational initiatives which will underpin the
quality of our policy development, our connection to real consumer experience and our
ability to make an impact on behalf of consumers.
Organisational development
Below are the organisational development projects we think will enable Consumer Focus
to most effectively deliver our work and prepare for the future.
1. Consumer Conditions Survey 2011
We will conduct a new UK-wide Consumer Conditions Survey (CCS). It will be a key
source of evidence for determining high level priorities for 2011-12.
The survey will provide new baseline information on consumer views, across the UK, on
most private sector markets and link in to the CCS in public sector markets in the 2010
survey using a comparable set of questions.
We aim to:
strengthen our ability to determine priorities that reflect consumer needs, thus ensuring that attention is focused on the areas of greatest need
2. Information and consumer behaviour change
Effective information is crucial to protect consumers from harm, help them make better
choices and ensure markets work effectively. We want to make sure that the information
provided to consumers takes into account their needs, and ensure that Government and
businesses do not overload consumers with information.
The project builds on existing expertise within Consumer Focus to bring together a
comprehensive list of consumer principles concerning communication and the provision
of information. These will be applied to a variety of markets, to provide us with case
studies showing both good and bad practice. We will use these principles along with the
case studies to advocate for improved consumer focused information provision with
NGOs, business and Government at UK, EU and global levels.
Draft Annual Plan 2010-11 for consultation 52
We aim to achieve:
a consolidated and comprehensive list of consumer principles concerning communication and information provision
improved information provision by NGOs, business and Government
a strengthened knowledge base for Consumer Focus to identify specific issues of communication and information provision
3. Behavioural economics, consumer interest and financial markets
It is normally assumed that consumers behave perfectly and have the time and skill to
make ‘optimal decisions’. The reality is that consumers are short of time, have unspecific
and inconsistent preferences, and cannot always calculate the best product for them.
Behavioural economics attempts to understand and compensate for the ‘imperfect’
consumer in policy making and product design. This work will review thinking on
behavioural economics and apply it to Consumer Focus's activities regarding consumer
behaviour, product and service design and best practice in regulation.
We will apply lessons learnt from this approach to two financial services markets in order
to gain insights into how to improve their function for consumers.
We aim to ensure that:
Consumer Focus is better able to respond to areas of consumer detriment based on insights into consumer behaviour
financial inclusion is improved by helping overcome the barriers of complexity and lack of trust
Over the longer term, these impacts will help to ensure that:
Consumer Focus is in a stronger position to argue for greater consumer welfare and financial inclusion
there is a richer engagement between Consumer Focus, regulators and market participants on the design and promotion of products and the operation of markets
4. Consumer empowerment
This work will build on current activities in energy and post to develop an innovative and
effective new consumer empowerment model. It will draw on work by predecessor bodies
and harness existing structures in the wider advice provision community.
We will develop targeted online empowerment resources, consumer information
(including energy pricing comparison) and generalist agencies (via our Partners’ website
and Knowledge Base). This will support the work of the new Consumer Advocate,
scoping new markets for empowerment provision, building relationships with key partners
in other markets to raise our profile, and identifying trends to address consumer
detriment.
Working with advice providers ensures that a wide range of consumers are made aware
of their rights and options. Harder to reach consumers will also gain access to Knowledge
Base information that is factual and up to date
We aim to:
consolidate and strengthen the existing consumer empowerment approach to support the information and advice function of the Consumer Advocate
Draft Annual Plan 2010-11 for consultation 53
improve and hasten the ability to communicate new policy developments to a wider audience
establish new sources of consumer intelligence
continue to develop Consumer Focus’s sound evidence base
drive up overall service standards in the energy industry, as consumers are made more aware of their rights and put pressure on industry to deliver them
5. Evaluating impact
This project is intended to develop a common structure and standard of practice for
evaluating the impact of Consumer Focus’s advocacy and policy change work.
It should ensure a better standard of practice allowing Consumer Focus to apply strategic
learning to future work, ensuring that the value delivered to consumers continues to
increase over time.
We aim to:
strengthen organisational transparency and capacity to plan, evaluate and demonstrate (with credibility) the impact of our work
improve management of our advocacy and policy work
improve ability to demonstrate a theory of change in the work we undertake
improve strategic planning, programme implementation and project planning
6. Annual reputation audit
We will conduct an annual survey of stakeholders to establish the perceived performance
of Consumer Focus, its senior management and staff. Careful consideration will be given
to ensuring proper representation of national stakeholders and the ability to report
separately across Consumer Focus, Consumer Focus Scotland, Consumer Focus Wales
and Consumer Focus Post (Northern Ireland).
Consumers will benefit from a better allocation of resources and better focus on
communicating to stakeholders about what we do, why we do it and why it makes a
difference to consumers.
We aim to:
improve the way we operate and communicate to achieve core goals. There could be changes in focus, in operating procedures, in work priorities or in communications
7. Rural consumers
We will develop a rural consumer policy and campaigns strategy to strengthen our
capacity to advocate on behalf of rural consumers in sectors where they face particular
detriment.
Rural policy is a devolved area in Scotland and Wales.
Our focus will be to ensure that rural consumers will be more empowered to take action
when they suffer detriment and should make better informed purchasing decisions.
We aim to:
improve policy and practice within Consumer Focus.
strengthen our capacity to advocate in the best interests of rural consumers
Draft Annual Plan 2010-11 for consultation 54
create greater public awareness of our work on behalf of rural consumers and among key decision makers
8. Staff engagement framework
With the prospect of more change on the horizon in the form of a new CEO and the
introduction of a proposed Consumer Advocate it is important that we make employee
engagement a priority area to ensure people remain focused and motivated to achieve
our overall objectives.
The work planned comprises three separate projects but they are all interlinked:
the development and delivery of a staff engagement survey
the development and delivery of a staff event
the development and implementation of a staff engagement framework
By creating an environment where staff feel empowered with a clear purpose and sense
of direction there will be a greater sense of communal ownership and accountability for
what the organisation must achieve. This should result in lower turnover of staff, fewer
sick days and a workforce that is motivated to deliver for consumers at the highest level.
We aim to ensure:
staff have a better understanding of our strategic direction and priorities
trust and confidence in senior management and their decision-making processes
staff feel empowered, valued and trusted to get on with the job
a competent and confident two-way communication culture
9. European and international stakeholder engagement
Develop and roll out stakeholder engagement strategy on the European and international
level in order to:
build our profile within the European/international institutions and develop partnerships with stakeholders campaigning on similar policies
increase our role within, and influence work plans and policy positions of, BEUC (the European consumer organisation), Transatlantic Consumer Dialogue and Consumers International through our membership
ensure the early identification and assessment of draft new policies likely to impact upon UK consumers and the effective engagement of Consumer Focus to inform the policy and legislative processes
raise awareness within the European/international institutions of evidence of new or continuing cases of consumer detriment and initiate action to address this
We aim to:
raise Consumer Focus’s profile on some issues, raise awareness of some issues on the EU level and promote our policies
Draft Annual Plan 2010-11 for consultation 55
10. Market studies and intelligence gathering
This work will explore opportunities to broaden our research and policy role at the EU and
international level. It will also identify potential for cross-country research projects that
support our work programmes. Our intelligence gathering and cross-country research will
reveal consumer detriment and will be the key vehicle to foster consumer protection
especially in the markets which have transnational dimension.
We aim to:
develop our engagement, influence and leadership in European and international policy making through building research base and the development of cross-country projects on issues that have transnational dimensions
11. Embedding a sustainability strategy within our work
We seek to embed sustainability as an essential component in everything we do. In
2010-11 we will examine our approach and undertake work to develop and embed a
strategic approach to sustainability in all that we do.
We aim to:
refine our approach to corporate planning to ensure due account is taken of sustainability in our work
target resources efficiently and effectively to enable Consumer Focus to add value in a crowded landscape
Draft Annual Plan 2010-11 for consultation 56
Pride in Performance
Evaluating success We use a balanced scorecard approach to measure and report on our work. The balanced scorecard offers a performance model to evaluate the areas in which we must excel in order to most effectively deliver a fair deal for consumers. Our success is measured across four distinct perspectives, and against a number of strategic objectives within each, as shown below.
Consumers and stakeholders
‘Achieving positive outcomes for
consumers’
Learning and development
‘Sustaining our ability to change and
improve’
To deliver the programmes set out in the
Annual Plan
To provide high quality customer service
to support vulnerable people with
complaints about energy and postal
services, via the Extra Help Unit
To be seen by consumers and
stakeholders as being influential and to
have an impact
To ensure the continuous development of
employee skills and expertise
To promote high staff performance by
ensuring that staff feel valued and
motivated
Process and innovation
‘Having efficient operations and internal
processes’
Financial management
‘Achieving results in an efficient manner
that minimises costs’
To deliver high priority and effective
corporate services activities
To promote effective cross-collaboration
and a co-ordination of efforts in delivering
our work
To provide realistic financial forecasts and
monitor expenditure against budget, using
property efficiently and effectively
To ensure value for money and promote
cost savings
We will use key performance indicators (KPIs) to track our progress against each objective for the year in question. The KPIs are kept under review to ensure they truly reflect the key drivers of our work and provide appropriate information with which to manage the organisation.
Draft Annual Plan 2010-11 for consultation 57
Funding and risks
Budget 2010-11
The core operational budget for 2010-11, covering basic running costs and the forward
work programme, will be similar to the current year which is £15m. There will be some
changes between years, with an anticipated funding reduction on the Department for
Business, Innovation and Skills (BIS) financed work of 10 per cent (£600,000) offset by
additional BIS funding for the new Consumer Advocate.
In 2010-11 it is estimated that we will spend £5.7m in our work for energy customers and
£3.4m in relation to consumers of relevant postal services. These figures will be finalised
after consultation on the draft Annual Plan and the separate consultation on the new
Consumer Advocate. They will be set out in the final version of our Annual Plan to be
published in March 2010.
These figures exclude ongoing property liability costs and externally funded projects
which are currently the work of the National Social Marketing Centre (NSMC) and work
undertaken for the Scottish Government. The budgets for these areas will be finalised in
early 2010.
For illustrative purposes only, our main funding streams for 2009-10 can be represented
as follows:
Draft Annual Plan 2010-11 for consultation 58
How to respond
Our consultation runs from 9 November 2009 to 9 February 2010. Comments on the
annual plan can be sent to any of our offices:
Consumer Focus:
Lord Whitty
Chair
Consumer Focus
4th Floor, Artillery House
Artillery Row
London
SW1P 1RT
Or alternatively you can email:
consultation.responses@ consumerfocus.org.uk
Consumer Focus Scotland:
Douglas Sinclair
Chair
Consumer Focus Scotland
Royal Exchange House
100 Queen Street
Glasgow
G1 3DN
Or alternatively you can email:
consultation.responses-scotland@consumerfocus.org.uk
Consumer Focus Wales:
Vivienne Sugar
Chair
Consumer Focus Wales
3rd Floor, Capital Tower
Greyfriars Road
Cardiff
CF10 3AG
Or alternatively you can email:
consultation.responses-wales@consumerfocus.org.uk
Consumer Focus Post (Northern Ireland):
Rick Hill
Chair
Consumer Focus Post
Elizabeth House
116 Holywood Road
Belfast
BT4 1NY
Or alternatively you can email:
consultation.responses-post@consumerfocus.org.uk
Draft Annual Plan 2010-11 for consultation 59
Questions for stakeholders
This consultation seeks your views on – four key questions:
1. What are your views on our proposed projects for 2010-2011?
2. How can they be improved? Are there any that should be dropped?
3. Are there other projects you feel we should be involved in? Please specify these and explain why.
4. To which projects should we give priority?
Next steps
Following the consultation period, we will review responses in February 2010 and submit
the final Plan to the Consumer Focus Board for sign off at its meeting on 25 March 2010.
Draft Annual Plan 2010-11 for consultation 60
Consumer Focus Draft Annual Plan 2010-11 for consultation 9 November 2009 – 9 February 2010
www.consumerfocus.org.uk
Copyright: Consumer Focus
Published: November 2009
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From a textphone, call 18001 020 7799 7900
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Consumer Focus
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Artillery House
Artillery Row
London SW1P 1RT
Tel: 020 7799 7900
Fax: 020 7799 7901
Media Team: 020 7799 8004 / 8005 / 8006
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